You (or your AFSL) would need a full standard AML/CTF Program (Parts A & B) only if you begin providing a designated service directly, such as:
- Operating a managed discretionary account (MDA)
- Issuing, providing, or operating a financial product yourself
- Providing remittance or payment services
- Dealing directly with client assets or funds in a way that constitutes a designated service
If your AFSL provides any designated service beyond the item 54 arranging service, a full AML/CTF Program is required.