--- title: "AML Risk Assessment Examples | HeadStart Docs" description: "Examples of how businesses document AML/CTF risk assessments. Common controls, risk rating approaches and documentation structures used across sectors." lang: en-AU json-ld: | [ { "@context": "https://schema.org", "@type": "Organization", "name": "HeadStart Docs", "legalName": "HeadStart Docs Pty Ltd", "url": "https://www.headstartdocs.com.au", "logo": { "@type": "ImageObject", "url": "https://www.headstartdocs.com.au/logo-512.png?v=4", "width": 512, "height": 512 }, "description": "AML/CTF compliance digital products and programs for Australian businesses under Tranche 2 regulations. Free program documents and AML Portal. 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We provide digital products for AML/CTF compliance, not legal services." } }, { "@context": "https://schema.org", "@type": "BreadcrumbList", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://www.headstartdocs.com.au/" }, { "@type": "ListItem", "position": 2, "name": "Shop", "item": "https://www.headstartdocs.com.au/shop" }, { "@type": "ListItem", "position": 3, "name": "Tranche 2 Hub", "item": "https://www.headstartdocs.com.au/tranche-2" }, { "@type": "ListItem", "position": 4, "name": "Sanctions Search", "item": "https://www.headstartdocs.com.au/sanctions-search" } ] }, { "@context": "https://schema.org", "@type": "FAQPage", "mainEntity": [ { "@type": "Question", "name": "Do I still need a solicitor for AML/CTF Tranche 2 compliance?", "acceptedAnswer": { "@type": "Answer", "text": "Yes. HeadStart Docs products are digital publications that give you a substantial head start, but they must be reviewed and tailored by a qualified solicitor to your specific business circumstances before implementation." } }, { "@type": "Question", "name": "How is HeadStart Docs different from the free AUSTRAC Starter Kits?", "acceptedAnswer": { "@type": "Answer", "text": "AUSTRAC Starter Kits are generic starting points that require significant customisation. HeadStart products are sector-specific, pre-populated with industry-relevant risk factors and scenarios, and include 12 months of AML Portal access for ongoing compliance including screening, record keeping and reporting tools." } }, { "@type": "Question", "name": "What if the AML/CTF rules change after I purchase?", "acceptedAnswer": { "@type": "Answer", "text": "Your digital products are yours to keep. If significant regulatory changes occur, updated versions will be available to active portal subscribers. 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All reporting entities in designated sectors including lawyers, accountants, real estate agents, conveyancers, and trust and company service providers must have their AML/CTF programs in place by this date." } } ] }, { "@context": "https://schema.org", "@type": "BreadcrumbList", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://www.headstartdocs.com.au/" }, { "@type": "ListItem", "position": 2, "name": "Free Resources", "item": "https://www.headstartdocs.com.au/tranche-2-resources" }, { "@type": "ListItem", "position": 3, "name": "Risk Assessment Documentation", "item": "https://www.headstartdocs.com.au/tranche-2-resources/risk-assessment-documentation" } ] }, { "@context": "https://schema.org", "@type": "Article", "headline": "AML/CTF Risk Assessment: Documentation Examples and Structure", "description": "Examples of how businesses document AML/CTF risk assessments. Common controls, risk rating approaches and documentation structures used across sectors.", "datePublished": "2025-12-13", "dateModified": "2025-12-13", "url": "https://www.headstartdocs.com.au/tranche-2-resources/risk-assessment-documentation", "image": "https://www.headstartdocs.com.au/logo-512.png", "inLanguage": "en-AU", "isPartOf": { "@type": "WebSite", "name": "HeadStart Docs", "url": "https://www.headstartdocs.com.au" }, "about": { "@type": "Thing", "name": "AML/CTF Compliance", "description": "Anti-Money Laundering and Counter-Terrorism Financing compliance for Australian businesses under Tranche 2" }, "author": { "@type": "Organization", "name": "HeadStart Docs" }, "publisher": { "@type": "Organization", "name": "HeadStart Docs", "logo": { "@type": "ImageObject", "url": "https://www.headstartdocs.com.au/logo-512.png" } } } ] --- [Get Started ](/checkout) We use cookies to enhance your experience and analyse traffic. [Privacy Policy](/privacy) Essential OnlyAccept All [Skip to main content](#main-content) [ ![HeadStart Docs](/assets/logo-dark-bg-CUivuKJ8.png)![HeadStart Docs](/assets/logo-light-bg-D5BRMGqf.png) ](/) [Home ](/) Features [Programs ](/programs) Resources Sectors [Log in ](/auth) [Portal](/aml-landing) ![AML/CTF risk assessment documentation](/assets/open-plan-office-Bj6Ewzk-.jpg) [Back to Free Resources](/tranche-2-resources) 13 December 2025 • Documentation # AML/CTF risk assessment: Documentation examples and structure The risk assessment component of an AML/CTF program typically involves documenting how your business identifies, assesses and manages ML/TF/PF risks. This article provides examples of how businesses commonly structure their risk assessment documentation. ## What businesses typically record A risk assessment generally documents several categories of information. The specific content depends on your business, designated services and risk profile. Common elements include: **Business context** Description of your business, services offered and which services are designated services **Risk categories** Categories of risk relevant to your business (customer, service, geographic, channel) **Risk identification** Specific risks identified within each category **Risk rating methodology** How risks are rated (e.g., low, medium, high) and the criteria used **Controls** Measures in place to manage identified risks **Residual risk assessment** Risk level remaining after controls are applied ## Examples of controls commonly documented Controls are the measures businesses put in place to manage identified risks. The following are examples of controls that businesses commonly document. The appropriate controls for your business depend on your specific risk assessment. ### Customer-related controls - Customer identification and verification procedures - Beneficial ownership identification processes - Politically exposed person (PEP) screening - Sanctions list screening - Ongoing customer due diligence triggers - Enhanced due diligence procedures for higher-risk customers ### Transaction-related controls - Transaction monitoring procedures - Threshold transaction reporting processes - Unusual transaction identification criteria - Cash handling protocols (if applicable) - Third-party payment procedures ### Operational controls - Staff training and awareness programs - Suspicious matter escalation procedures - Record keeping and retention policies - Compliance officer appointment and responsibilities - Independent review schedule ## Risk rating methodology examples Businesses typically use a rating system to categorise risks. Common approaches include: ### Three-tier rating (Low, Medium, High) #### Low risk Examples: Long-standing customers, straightforward transactions, low-value services, customers from low-risk jurisdictions #### Medium risk Examples: New customers, higher-value transactions, some complexity in ownership structure, customers from moderate-risk jurisdictions #### High risk Examples: Complex corporate structures, customers from high-risk jurisdictions, politically exposed persons, large cash transactions, unusual transaction patterns ### Inherent vs residual risk Many businesses document both: - **Inherent risk:** The risk level before controls are applied - **Residual risk:** The risk level after controls are applied This approach helps demonstrate how controls reduce risk to an acceptable level. ## Documentation structure examples There is no single required format for risk assessment documentation. Common structures include: #### Narrative format A written document describing the business, its risks and how they are managed. Suitable for smaller or less complex businesses. #### Risk register format A spreadsheet or table listing each risk, its rating, controls and residual risk. Useful for tracking and reviewing multiple risks systematically. #### Hybrid format A narrative overview supported by risk register tables for specific categories. Common for medium-sized businesses. ## Risk considerations by sector Different sectors may face different risk profiles. Examples of risks by sector that businesses commonly document include: #### Legal Professionals Trust account handling, conveyancing transactions, complex client structures #### Accounting Professionals Business sale facilitation, client fund management, tax planning structures #### Real Estate Professionals High-value property transactions, international purchasers, cash deposits #### TCSPs Company formation services, nominee arrangements, beneficial ownership complexity #### Precious Metals Dealers Cash transactions, high-value items, anonymous purchaser risk #### Regular review Risk assessments typically require regular review to remain current. Many businesses review their risk assessment annually, or when significant changes occur (new services, new customer types, regulatory changes). ## Questions to discuss with your adviser - What risk categories are most relevant to your designated services? - How should you document controls already in place? - What rating methodology is appropriate for your business size and complexity? - How often should your risk assessment be reviewed? - Who should be involved in the risk assessment process? - How does your risk assessment connect to your compliance procedures? [ Read our complete Tranche 2 Guide Key dates, affected sectors, obligations and how to prepare ](/tranche-2) ### Start your documentation efficiently HeadStart Docs™ provides free sector-specific compliance documents including risk assessment frameworks. All documents require legal review and tailoring. [View Digital Products](/programs)[Implementation Plan](/products/implementation-plan)[Readiness Assessment](/risk-calculator) **Disclaimer:** This article is general information only. It is not legal, financial or compliance advice. HeadStart Docs™ provides free compliance documents, not legal services. We do not guarantee the accuracy of information provided. Obligations may apply depending on your designated services. Always confirm your specific requirements with a qualified adviser. Need a lawyer to review your AML/CTF program? [HeadStart Counsel](https://headstartcounsel.com.au/get-started) offers fixed-fee tailoring from $1,800+GST. 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