AML/CTF Program
Wizard & Management
Build your firm's AML/CTF program with a guided wizard. Version-controlled with approval workflows, AMLCO appointment records, and independent review tracking — so you always have the current authorised version on file.
How It Works
Every reporting entity must have an AML/CTF program. Sentine's program wizard guides your firm through building Part A (risk, governance, controls) and Part B (CDD/KYC procedures, verification procedures, ongoing CDD procedures) of your program — tailored to your specific vertical and designated services.
Program documents are version-controlled with a full change log. Each version records what changed, why, and who approved it. The current authorised version is always clearly identified, and superseded versions are retained for audit purposes.
The governance module tracks AMLCO appointment and responsibilities, program approval records, training evidence, and the 3-yearly independent review cycle. Sentine calculates your next review due date and provides reminders to firm administrators.
Step by Step
Follow the structured workflow from start to finish.
Program Wizard
Answer guided questions about your firm's services, risk profile, and compliance structure. The wizard generates your program framework.
Part A & Part B Generation
Generate Part A (risk, governance, controls) and Part B (CDD procedures, verification procedures, ongoing CDD) documents based on wizard answers.
Review & Approval
Route the draft program for review and approval. Record the approver, approval date, and version number.
AMLCO Appointment
Record AMLCO appointment details, responsibilities, and delegation authorities as part of your program governance.
Ongoing Management
Track program versions, training register, and independent review cycle. Update your program as regulations or firm circumstances change.
Key Features
Everything you need for this workflow, built into the platform.
Guided Program Wizard
Step-by-step wizard tailored to your vertical (accounting or real estate) and designated services.
Version Control & Change Log
Every program version is tracked with what changed, why, and who approved. Current authorised version clearly identified.
Part A & Part B Structure
Generated program follows the Part A (governance) and Part B (procedures) structure expected by AUSTRAC.
AMLCO Appointment Record
Formal record of AMLCO appointment, responsibilities, and delegation authorities within the program.
Training Register
Track staff AML/CTF training completion, schedule refreshers, and maintain evidence of ongoing training obligations.
Independent Review Tracking
3-yearly independent review cycle tracking with due date calculation, reviewer records, and remediation action tracking.
AML/CTF Program Requirements
The reformed AML/CTF Act requires reporting entities to have an AML/CTF program that addresses their specific ML/TF risks. Programs must be independently reviewed at least once every 3 years. Sentine helps firms build, maintain, and version their programs with complete governance records — including AMLCO appointment, approval workflows, and review tracking.
- AML/CTF programs: Part A (governance) + Part B (procedures)
- Independent review required at least every 3 years
- AMLCO appointment and responsibilities must be documented
- Program must be updated when risks or circumstances change
Explore Related Features
See how this capability connects to the broader compliance workflow.
Audit Trail
Program changes, approvals, and review events are logged in the immutable audit trail.
Learn moreMatter Workflow
Your program defines the procedures that matter workflows implement in practice.
Learn moreAUSTRAC Reporting
Your program establishes the reporting procedures for TTR, IFTI, and SMR obligations.
Learn moreBuild Your AML/CTF Program
Guided wizard with version control, approval workflows, and independent review tracking.
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