FAQ

When would an adviser or AFSL need a full AML/CTF Program?

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.

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