Read the decision before opening every attachment
Start with the designated service, customer population, risk assessment and proposed next act. Ask what the file is meant to establish. Then follow the links to the relevant evidence. Where a conclusion rests on an exception, identify its basis and conditions. This is more useful than marking a folder complete because an engagement letter, identity image and company extract are present, without checking what each item demonstrates.
Check the links between evidence and conclusions
Compare names, identifiers, capacities, dates and relevant roles across the records. Look for material conflicts, unexplained control links, obsolete authority and a mismatch between the assessed purpose and the instructions being carried out. AUSTRAC's record-keeping guidance focuses on sufficient records of compliance and reconstruction. Use a proportionate review that tests those connections instead of adding forms that repeat the same unsupported assertion in several places.
Make open actions specific and owned
For example, write that the new director's authority to instruct must be confirmed before the formation step, rather than leaving a general note to finish KYC. Record who will obtain the information, who decides if it is adequate and what work is restricted meanwhile. An unresolved screening alert should have a decision owner and supporting facts. Do not bury a material exception in a general comments field that the receiving staff member may miss.
Preserve the review and make it actionable
Record the reviewer, date, evidence considered, conclusion and any limits. Transfer ownership of outstanding work explicitly and confirm the recipient can access the authorised records. Keep protected reporting material separately restricted. If the file is later corrected, preserve the necessary history and reconsider affected decisions. Repeated review findings should inform training and program improvements, not merely be corrected in the individual file and forgotten.
Official sources
Use these primary sources to confirm the current rules and apply them to your circumstances.
Sources checked .
Frequently asked questions
Is a file review an independent program evaluation?
No. A case review tests particular work. An independent evaluation assesses the program under its separate requirements and agreed scope.
Does a complete document checklist prove the decision is sound?
No. The evidence must support the required matters and the actual service. Presence alone does not establish relevance, currency or a resolved conflict.
What should the receiving staff member see first?
The current service decision, work boundary, material risks and owned open actions, with links to the underlying evidence and review history.
Put it into practice
Cassandra AML turns these obligations into a working system: designated-service decisions, customer due diligence, screening, monitoring and reporting records — hosted in Sydney, free to start.
This guide is general information for Australian professionals. It is not legal advice and does not replace the AML/CTF Act, the AML/CTF Rules or AUSTRAC guidance. Confirm your specific obligations with AUSTRAC or a qualified legal adviser. See our editorial and correction standards.