Financial planners holding an AFSL who only provide item-54 designated services have a tailored AML/CTF profile.
Key concepts
What still applies
Risk assessment
Document your ML/TF risk picture.
Initial CDD policies
Apply CDD to new customer relationships.
Reporting
SMR, TTR and IFTI reporting where triggered.
Record-keeping
At least 7 years.
Item-54 exemption
Some governance and ongoing-CDD obligations may be tailored — but the core AML/CTF program duties remain.