AML/CTF Policy
How we meet our obligations under Australia’s anti-money laundering and counter-terrorism financing regime. Last updated 10 August 2026.
This policy explains how SMA Business Advisory meets its obligations under Australia’s anti-money laundering and counter-terrorism financing regime, and what that means for you as a client.
1. Our obligations
Where SMA Business Advisory Pty Ltd provides, or expects to provide, a designated service under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and the Anti-Money Laundering and Counter-Terrorism Financing Rules 2025 (together, the AML/CTF regime), administered by AUSTRAC (the Australian Transaction Reports and Analysis Centre), we’re required to comply with all applicable rules and obligations under that regime. This includes enrolling with AUSTRAC and maintaining an AML/CTF program appropriate to the services we provide.
2. What this means for clients
Where we provide a designated service to you, we’re required to:
- verify your identity, and where relevant the identity of any beneficial owners or controllers connected to your business or trust, before we provide the service
- understand the nature of your business, the purpose of the engagement, and where relevant the source of the funds or wealth involved
- monitor the engagement on an ongoing basis for unusual activity
- retain relevant records for at least seven years
If we ask for identification documents or additional information you haven’t been asked for before, it reflects a legal obligation on us, not a judgement about you. Where further verification is needed, you may be contacted directly by InfoTrack, the platform we use to manage this process. This is a legitimate part of our compliance process, not unsolicited contact.
3. Engaging our services
There may be situations where identification or due diligence checks can’t be completed, or where risk, professional or legal considerations require it. In these situations we may decline to begin an engagement, or pause or end one already underway. By engaging us for a designated service, you acknowledge and consent to the collection, verification, use and disclosure of your information to the extent required by the AML/CTF regime and our other professional obligations.
4. Confidentiality of reporting
Where the law requires us to report a matter to AUSTRAC, we’re prohibited from telling you, or anyone else, that a report has been made. This is a statutory restriction, often called the “tipping off” offence, rather than a discretionary choice on our part.
5. More information
General information about Australia’s AML/CTF reforms is available directly from AUSTRAC at austrac.gov.au. If you have questions about this policy, contact us at manraj@smabusinessadvisory.com.au.
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