White-Label AML/CTF Program Templates — Disclaimer

1  About SIAC and These Templates

SIAC (Strategic Intelligence & Advisory Compliance) is a Melbourne-based AML/CTF advisory practice that develops and publishes professional-grade white-label compliance templates for reporting entities entering the Australian AML/CTF framework under the Tranche 2 reforms.

1.1  What SIAC Is

SIAC operates the platform siac.com.au and produces AML/CTF program templates, operational registers, checklists, and supporting compliance resources for professional services firms. SIAC is not a law firm and does not hold an Australian Financial Services Licence. SIAC does not provide legal or financial advice, and is not the AML/CTF Compliance Officer of any firm to which its templates are supplied.

SIAC's website Terms & Conditions and Privacy Policy apply to all use of the siac.com.au platform and are available at siac.com.au. Those documents govern your access to and use of the website and digital products available through it. This Disclaimer governs the use of the template documents themselves.

1.2  The Template Suite

SIAC has developed sector-specific AML/CTF program templates for the following Tranche 2 reporting entity categories, operative from 1 July 2026:

• Conveyancing practices — licensed conveyancers providing Table 6 conveyancing services
• Legal practices — law firms and barristers providing Table 6 designated legal services (Items 1–9)
• Real estate agencies — agents providing designated real estate sale and acquisition services
• Accounting and professional services — tax agents, accountants, and TCSP service providers
• Jewellers, precious metals and bullion dealers — subject to the $10,000 AUD cash threshold

Each template is a pre-populated, sector-calibrated compliance framework containing governance structures, risk assessment methodology, CDD and EDD procedures, suspicious matter reporting protocols, training frameworks, and a full suite of operational registers and checklists.

3  Your Responsibility — Risk Assessment and Adaptation

3.1  You Must Assess Your Own Risk

The AML/CTF Rules 2025 require every reporting entity to conduct and maintain an enterprise-wide ML/TF risk assessment (EWRA) specific to its own business. The risk framework in SIAC's templates provides methodology, scoring structure, and documentation architecture. It cannot pre-populate your actual risk scores, inherent risk ratings, or risk appetite — those are judgements about your specific business that only you can make.

You must:

• Conduct a genuine, documented enterprise-wide risk assessment reflecting your actual client base, services, delivery channels, geographic exposure, transaction volumes, and ownership structure.
• Determine and document your own risk appetite and apply it operationally across client acceptance, transaction monitoring, and EDD triggers.
• Update the risk assessment promptly when there is any material change to your business, client profile, or regulatory environment — not only at the annual review.
• Obtain governing body review and formal written approval of the completed risk assessment before the program is adopted and operative.

3.2  Customisation Is Mandatory

A template in its original, uncustomised form is not your AML/CTF program. Presenting an uncustomised template to AUSTRAC or any other party as evidence of compliance is misleading and may itself constitute a regulatory breach. Before adopting any template, you must complete all of the following:

• Complete all yellow-highlighted placeholder fields with your actual entity name, ABN, AUSTRAC enrolment number, Compliance Officer details, and all other required information.
• Populate the enterprise-wide risk assessment with your own risk scores and actual risk ratings — illustrative scores in the template carry no regulatory weight until replaced with your firm's own assessment.
• Review and scope the designated services list to reflect only the services your firm actually provides.
• Verify all procedures against your actual systems, technology, staffing, and controls — amend where the template does not accurately describe how your firm operates.
• Identify and remove or adjust any sector-specific provisions that do not apply to your firm before adoption.
• Have the program formally reviewed and approved in writing by your governing body before it becomes operative.

3.3  You Are Responsible for Suitability

SIAC does not assess whether any template is suitable for any particular firm. The decision to use a template is entirely yours, based on your own assessment of whether it is appropriate for your business model, regulatory classification, and risk profile. You should consider:

• Whether the sector template corresponds to your primary designated service category under the AML/CTF Act 2006 (Cth).
• Whether your firm provides additional designated services not fully addressed by the template, which may require supplementary procedures.
• Whether your firm's scale, structure, or complexity creates ML/TF risk that goes beyond the template's baseline assumptions.
• Whether the template needs to be integrated with or reconciled against any existing policies or systems.

3.4  Annual Review Remains Your Obligation

The AML/CTF Rules 2025 require your firm to review its AML/CTF program at least annually and more frequently upon any material change to the business or regulatory environment. This is your legal obligation. SIAC does not conduct this review on your behalf and has no ongoing commitment to update templates in response to regulatory changes unless separately agreed.

4  No Liability

4.1  SIAC Accepts No Responsibility for Compliance Outcomes

To the maximum extent permitted by law, SIAC, its contributors, and any individuals involved in producing these templates expressly exclude all liability for any loss, damage, penalty, regulatory action, enforcement outcome, or other consequence of any kind arising from or connected with:

1. Accessing, downloading, using, or relying upon any SIAC template in any form.
2. Any failure to customise a template to reflect your actual operations, risk profile, or regulatory obligations.
3. Any failure of a template-based program to meet the requirements of AUSTRAC, any regulator, or any court or tribunal.
4. Any regulatory action, civil penalty, or enforcement outcome arising from your firm's AML/CTF compliance posture.
5. Any error, omission, inaccuracy, or regulatory currency issue in any template, including any failure to reflect changes to law or guidance after the template's effective date.
6. Any reliance by any third party on the content of a SIAC template.

4.2  No Guarantee of Compliance

SIAC does not warrant or guarantee that use of any template will result in compliance with the AML/CTF Act 2006 (Cth), the AML/CTF Rules 2025, or any other law or guidance. Whether a reporting entity is compliant is determined by AUSTRAC based on the entity's actual conduct and risk management — not by the existence of a written program document.

4.3  Australian Consumer Law

Nothing in this disclaimer excludes any right or guarantee that cannot be excluded under the Australian Consumer Law (Schedule 2, Competition and Consumer Act 2010 (Cth)). Where a non-excludable guarantee applies, SIAC's liability is limited to the extent permitted by law.

5  Intellectual Property and Permitted Use

5.1  SIAC's Intellectual Property

The structure, frameworks, risk methodologies, procedural content, and appendix designs in SIAC templates are the intellectual property of SIAC. You may use, adapt, and implement a template for the purpose of developing your own firm's AML/CTF program. You retain ownership of all content you generate during that process — your risk scores, procedural variations, client data, and approval records are yours.

5.2  What You Must Not Do

Without SIAC's prior written consent, you must not:

• Reproduce or distribute SIAC template content in a form that competes with or substitutes for SIAC's published products.
• Represent a template in its original or minimally adapted form as a complete or compliant AML/CTF program authored by you.
• Use any SIAC template content to train, develop, or prompt any artificial intelligence or machine learning system.
• Share download access to templates with individuals or organisations who have not separately obtained access through SIAC.

5.3  Referencing SIAC

When using or referencing a SIAC template, you must not misrepresent SIAC's role, identity, or legal structure. SIAC is not a Pty Ltd company, is not a law firm, and does not act as your compliance officer. Do not describe SIAC in any way that implies a formal regulatory or advisory engagement exists unless you have a separate written agreement with SIAC to that effect.

6  Regulatory Basis and Currency

The Version 2.0 SIAC template suite is developed by reference to the following legislative and regulatory framework as at 1 July 2026:

• Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), as amended by the AML/CTF Amendment Act 2024 (Cth)
• Anti-Money Laundering and Counter-Terrorism Financing Rules 2025 (tabled 29 August 2025)
• AML/CTF (Transitional) Rules 2026
• AUSTRAC sector-specific AML/CTF Program Starter Kits — Conveyancers, Legal Practitioners, Real Estate Agents, Accountants, and HVD (published January–March 2026)
• FATF Recommendations (2023 edition) and relevant Mutual Evaluation Reports
• Autonomous Sanctions Act 2011 (Cth) and related instruments

SIAC does not commit to updating templates automatically in response to legislative or regulatory changes after the effective date. Monitoring regulatory developments and keeping your program current is your responsibility. The AML/CTF Reform Tracker appendix in each template is provided as a tool to support that process.

7  Website Terms, Privacy, and Further Information

SIAC's full Terms & Conditions and Privacy Policy apply to all use of siac.com.au, including access to and download of these templates. These documents are published on the website and should be read alongside this Disclaimer. They address matters including payment terms, refunds, data collection, and your rights in relation to information provided to SIAC.