> ## Documentation Index
> Fetch the complete documentation index at: https://docs.clearaml.com.au/llms.txt
> Use this file to discover all available pages before exploring further.
# Build and maintain your firm's AML/CTF program
> Upload or generate your AML/CTF program in ClearAML, schedule annual reviews, appoint a compliance officer, and track program status from the Compliance Hub.
Your AML/CTF program is the foundation of your firm's compliance obligations under the *Anti-Money Laundering and Counter-Terrorism Financing Act 2006* (Cth). ClearAML gives you a central place to upload or generate your written program, appoint a compliance officer, track review dates, and see your program status at a glance from the Compliance Hub dashboard.
The Tranche 2 reforms take effect on **1 July 2026**. From that date, accountants, lawyers, conveyancers, and real estate professionals are captured reporting entities required to have a compliant AML/CTF program in place. Firms without an active program will show an **At Risk** status in ClearAML.
## What is an AML/CTF program?
An AML/CTF program is a written document that describes how your firm identifies, mitigates, and manages its money laundering and terrorism financing risks. AUSTRAC requires that every captured reporting entity:
* Maintains a current, written AML/CTF program
* Reviews the program at least once every 12 months
* Appoints a nominated compliance officer responsible for the program
* Keeps records of each version, including decommissioned versions, for a minimum of 7 years
ClearAML stores every version you publish in a tamper-proof ledger and surfaces the active version on your Compliance Hub dashboard.
## Upload or generate your program
Navigate to **Compliance Hub** in the left sidebar. On the **Overview** tab you will see three quick-stat cards: **Program Status**, **AML/CTF Program**, and **Staff Trained**.
Click the **AML/CTF Program** card or, if your program status shows **At Risk**, click the card to open the Risk Factors sheet and select **Remediate Now** next to "AML/CTF Program Manual Missing". Both routes open the **View and Update AML/CTF Program** dialog.
The **Current Program** tab shows your active program document with its version number, activation date, assessed risk rating, key risk indicators, and next review date. Click **Download** to retrieve the file.
Click **Update Program** at the bottom of the dialog. This redirects you to the onboarding flow where you can generate a new program or upload your own document. Once published, the previous version moves to the **Decommissioned** tab and is retained for 7 years.
ClearAML can generate a draft AML/CTF program tailored to your firm type during onboarding. You can review, customise, and publish it directly — no blank page required.
## Appoint a compliance officer
AUSTRAC requires you to nominate a person responsible for your AML/CTF program. To record your compliance officer in ClearAML:
1. Go to **Settings → Team Management**.
2. Locate the team member you want to designate.
3. Set their role to **Officer** or **Admin** — these roles have write access to the program and compliance calendar.
Only users with the **Admin**, **Owner**, or **Compliance Officer** role can create compliance calendar events, mark events complete, or publish program updates.
## Schedule and track reviews with the compliance calendar
The **Compliance Workspace** panel on the right side of the Compliance Hub **Overview** tab shows all upcoming and overdue compliance events. Your active program's **Next Review Date** is automatically added as a calculated event when you publish a new version.
Click the **+** button in the Compliance Workspace header (visible to admins, owners, and officers). Fill in the event title, entity type (AUSTRAC, Internal, HR, or Audit), priority, assignee, and due date.
Hover over any non-statutory event and click the **⋯** menu that appears. Select **Mark Complete**. The action is recorded in the audit trail with a timestamp.
Events are colour-coded by status:
* **Overdue** — past due date, shown in red
* **Urgent** — due within 7 days, shown in orange
* **Upcoming** — due in more than 7 days, shown in blue
* **Completed** — shown in green, hidden by default (toggle with "Show completed")
Statutory and auto-calculated events (labelled **System** or **Auto**) are read-only. You cannot edit or delete them, but you can mark them complete.
## Program status card
The **Program Status** card on the Compliance Hub overview shows either **Compliant** (green) or **At Risk** (red). It turns red when:
* No active AML/CTF program is found for your firm
* The program's **Next Review Date** has passed without a new version being published
* One or more staff members have incomplete mandatory training modules
Clicking the **At Risk** card opens the **Risk Factors** sheet listing every item that needs attention, with a direct **Remediate Now** action for each.
## What AUSTRAC expects
Your program must document your firm's ML/TF risk assessment, covering the nature and scale of your designated services, your client types, delivery channels, and jurisdictions.
This section covers your customer identification and verification procedures (KYC), including when and how you collect, verify, and re-verify customer information, and how you handle PEPs, sanctions matches, and high-risk customers.
AUSTRAC expects you to review and, where necessary, update your program at least once every 12 months or after a significant change to your business. ClearAML tracks this date and flags it as overdue if a new version is not published within 12 months of the last approval.
You must keep records of your AML/CTF program for at least 7 years. ClearAML retains all versions — including decommissioned documents — in the **Decommissioned** tab of the program dialog. All records are stored in Australian data centres and encrypted at rest and in transit.