Features

Everything your firm needs, in one place

Nine connected modules take a client from onboarding through to reporting. Each produces a defensible record, and because they share the same data, nothing is re-keyed and nothing falls between tools.

app.cleartrace360.com.au — Firm risk assessment
Firm risk assessment · 6 factors
Designated servicesHigh
Customer typesMedium
Delivery channelsLow
Countries & PFMedium
Overall ratingApproved

Firm risk assessment

A guided, plain English questionnaire walks you through every AUSTRAC risk factor — designated services, customers, delivery channels, countries and proliferation financing. Each factor is rated, with a written rationale, and the overall rating is approved by a senior manager.

Example. A firm that forms companies and holds client money is guided to rate those services higher, and the assessment records why.
  • Impact-only or likelihood × impact methods
  • Country register from Basel, FATF and DFAT sources
  • Senior-manager approval and version history
Obligation: Risk assessment (s26C)Output: Approved firm risk assessment
app.cleartrace360.com.au — Program & policies
AML/CTF program generated
Part A · Risk assessmentReady
Part B · Policies & controlsReady
Customer due diligence policyReady
Record keepingReview

Program & policies

Your AML/CTF policies are generated straight from the risk assessment and tailored to the services you actually provide. Every version is dated, approved and retained, so you always know which policy applied when.

Example. When you add a new service, ClearTrace flags the policy sections that need review.
  • Policies matched to your designated services
  • Version control with approval log
  • Ready to export for AUSTRAC or an auditor
Obligation: AML/CTF programOutput: Approved, versioned policies
app.cleartrace360.com.au — KYC & KYB onboarding
Onboarding · Acme Holdings Pty Ltd
Identity verification (KYC)Verified
Beneficial owners (UBO)3 / 3
Sanctions screeningClear
Risk ratingEnhanced CDD

KYC & KYB onboarding

Digital onboarding for individuals, companies and trusts, including identification of beneficial owners. OCR reads identity documents and extracts the key fields, so staff re-key almost nothing.

Example. For a company client, ClearTrace maps the ownership chain and prompts for each beneficial owner at 25% or control.
  • Individuals, companies, trusts and partnerships
  • Beneficial-owner (UBO) identification
  • OCR extraction of name, DOB, address, document number
Obligation: Customer due diligenceOutput: A complete, verified client file
app.cleartrace360.com.au — Sanctions & PEP screening
Screening · results
DFAT Consolidated ListClear
Global sanctions sourcesClear
PEP statusMatch
Adverse media1 hit

Sanctions & PEP screening

Screening against the DFAT Consolidated List first, then UN, OFAC, EU and UK HMT. Fuzzy matching surfaces likely hits and an analyst reviews them, so genuine matches are caught and false positives cleared quickly.

Example. A near-match on the DFAT list is flagged for review rather than silently passed or blocked.
  • DFAT-first, plus global lists
  • Fuzzy matching with analyst review
  • Continuous re-screening as lists refresh
Obligation: Sanctions & PEP checksOutput: A screened client with an evidence record
app.cleartrace360.com.au — Risk-rating engine
Risk rating · outcome
Base risk score42
Country weighting+18
PEP flag+20
Overall pathwayEnhanced CDD

Risk-rating engine

Every client is scored from AUSTRAC risk factors and assigned Standard or Enhanced CDD. The rating updates automatically as data changes, and sanctions, foreign PEPs or hidden ownership force mandatory escalation.

Example. A foreign-PEP result moves a client to Enhanced CDD and routes it to a senior manager for approval.
  • Standard vs Enhanced CDD, computed live
  • Mandatory escalation overrides
  • Full rationale stored for every rating
Obligation: CDD level determinationOutput: A live client risk rating
app.cleartrace360.com.au — Ongoing monitoring
Monitoring alerts · 2 open
Sanctions refresh · M. ParkHigh
PEP change · D. HartleyMedium
Quarterly re-screen · 1,247Done
Trigger-event reviewActive

Ongoing monitoring

Clients are re-screened on trigger events and on a schedule set by their risk rating. Alerts are managed as cases, so nothing is missed and every decision is recorded.

Example. A change in a client’s ownership triggers an automatic review and re-screen.
  • Trigger-event and periodic reviews
  • Alerts handled as trackable cases
  • Re-screening against refreshed lists
Obligation: Ongoing customer due diligenceOutput: Continuous, case managed monitoring
app.cleartrace360.com.au — SMR & TTR reporting
Reporting · workflow
SMR draft · 2026-004In review
TTR · threshold transactionReady
Tipping-off controlsEnforced
AUSTRAC lodgementSecure

SMR & TTR reporting

A structured suspicion workflow with built-in tipping-off controls. Staff raise an internal escalation; the AML/CTF Compliance Officer reviews and lodges the report with AUSTRAC within the required timeframe.

Example. When a staff member forms a suspicion, the client is not alerted and the matter routes straight to the AMLCO.
  • Internal escalation, then AMLCO lodgement
  • Tipping-off controls (s123)
  • Timeframes tracked (3 business days; 24 hours for TF)
Obligation: Reporting to AUSTRACOutput: Timely, controlled reporting
app.cleartrace360.com.au — Training & personnel checks
Personnel · training register
Fit & proper checks12 / 12
AML inductionComplete
Annual refresher9 / 12
Role-based modulesAssigned

Training & personnel checks

Role-based AML/CTF training with completion tracking, plus fit and proper checks for the people in your AML function. New staff are screened before they touch client work.

Example. The compliance officer’s fit and proper record and reassessment date are held on file.
  • Role-based training with tracking
  • Fit and proper and screening records
  • Reassessment reminders
Obligation: Personnel due diligence & trainingOutput: Trained, screened personnel on record
app.cleartrace360.com.au — Records, evaluation & annual report
Records · 7-year trail
Immutable audit trailActive
Independent evaluationScheduled
Annual compliance reportDraft
Retention period7-year

Records, evaluation & annual report

A seven-year, tamper-evident audit trail of every action, plus tracking of independent evaluations and the AUSTRAC annual compliance report.

Example. When AUSTRAC asks for a two-year-old decision, the full record is one search away.
  • Seven-year, tamper-evident trail
  • Independent-evaluation tracking
  • AUSTRAC annual compliance report
Obligation: Record-keeping & reportingOutput: An always-ready evidence trail
Governance built in

The right people, the right approvals

ClearTrace mirrors AUSTRAC’s governance model. One person can hold several roles in a small firm; larger firms and reporting groups keep them separate.

Senior Manager

Approves the program, risk assessment and high risk / PEP clients.

Compliance Officer

AMLCO — oversight, reporting and AUSTRAC contact.

AML Staff

Run day to day CDD and ongoing transaction monitoring, and escalate to the Compliance Officer.

Auditor

Independent, read only review.

Reporting groups

One program across a lead entity and its members

Where a reporting group has a lead entity, ClearTrace runs one risk assessment and program that still captures each member entity’s services, customers, channels and countries — and one member lodges the annual compliance report for the group.

See the platform mapped to your obligations

A live walkthrough tailored to your firm’s services.

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