Australian AML/CTF · Explainer

What does it mean to reconstruct a transaction from records?

A reviewer should be able to follow what happened using linked evidence.

General information only, not legal, compliance, or other professional advice. Does not confirm compliance.

Start with: When does an AML program become a working process?

Reconstruction is an evidence test

Reconstructing a transaction means using records to establish what happened. Section 107 requires sufficient records to reconstruct individual transactions relating to the designated service.

The necessary details depend on the service. A payment entry can leave the parties, instructions or linked documents unclear.

Source: Federal Register of Legislation: 107, 118 and 119.

Follow a transaction through its recordsInstruction Action and changes Completed result Retrieval check
  1. Instruction

    Locate the original instruction and identify the parties.

  2. Action and changes

    Link the work performed, changes and payment information.

  3. Completed result

    Explain what occurred and why it differs from the original instruction, if applicable.

  4. Retrieval check

    Ask another person to locate the records and identify any missing links.

Follow a transaction through its records

Suggested reconstruction exercise. Preserve actual history and mark later explanations as retrospective.

Follow the process from top to bottom.

Link the records together

A practical design uses a consistent reference across instructions, documents and system entries. Link any change to the original instruction.

Show how several payments or actions relate to the transaction. Identify which entity provided the service.

Source: Federal Register of Legislation: 107, 118 and 119.

Invented example: a revised instruction

In a fictional matter, a customer changes an instruction before a payment. The file contains the first instruction and payment entry, but not the change.

The reviewer cannot explain the difference from those records alone. Staff locate the missing instruction and preserve its original date and source.

A later explanation must be labelled as a later explanation. Do not present it as a record made at the time.

Source: Federal Register of Legislation: 107, 118 and 119.

Run a retrieval exercise

Ask an authorised person to retrieve the evidence and explain the transaction. Identify gaps in the parties, amounts, timing or instructions.

This is a practical exercise, not a statutory test format. Use it after a system migration where relevant.

Section 107 has its own scope and retention period. Apply the relevant exemptions and other duties before disposal.

Source: Federal Register of Legislation: 107, 118 and 119.

Record the retrieval result

Record what the retrieval exercise established and what remains missing.

If a system change removed a link, correct the link and repeat the affected retrieval. A matching file count does not prove usable evidence.

Source: Federal Register of Legislation: 107, 118 and 119.

Sources and scope

Sources checked on 13 September 2026. This page is not continuously updated. Check the linked legislation and AUSTRAC guidance for current requirements.

How we prepare articles

This page does not cover: Specialist transfer record rules; Every statutory exemption.

Common AML/CTF terms