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FAQ

I’m an adviser — what type of AML/CTF Program do I need?

Usually, no.

Most individual advisers do not need a standalone AML/CTF Program because:

  • They operate under an AFSL, and
  • Their AFSL (or the product issuer) is the reporting entity for AML/CTF purposes.

If you are authorised under someone else’s AFSL, you usually follow their AML/CTF Program, not your own.

Where your AFSL only performs the item 54 “arranging” service (arranging for clients to receive a designated service), the licensee may need only a Special AML/CTF Program (Part B-only)

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