AML/CTF Advisory for Australia

Clarity on
AML/CTF
Compliance.

Expert AML/CTF compliance advisory for Australian businesses — from understanding your obligations for the first time, through to developing a compliant program and independent policy review.

1 Jul
Tranche 2 reforms in effect — 2026
7 yrs
Minimum record-keeping period required
24 hrs
To report terrorism financing suspicions
$10K
Threshold Transaction Report trigger
AML/CTF Obligations

I want to know my business's AML/CTF obligations

Understanding whether your business is subject to Australia's anti-money laundering laws is the essential first step — and the answer may surprise you. Size is not a factor. A one-person operation can be a reporting entity just as a major bank can be.

Am I under AML/CTF obligations?

You are a reporting entity if your business provides a designated service with a geographical link to Australia. The list of regulated businesses expanded significantly on 1 July 2026 under Tranche 2 reforms.

Currently regulated

Banks & Credit Unions
Mortgage Brokers
Digital Currency Exchanges
Remittance Businesses
Insurance Providers
Securities Dealers
Gambling Operators
Bullion & Pawnbrokers

Newly regulated from 1 July 2026 ›

Accountants
Lawyers & Conveyancers
Real Estate Agents
Trust & Company Services
Precious Metals Dealers
Virtual Asset Services

What are my obligations?

  • Enrol with AUSTRAC within 28 days of commencing a designated service (Tranche 2 entities: by 29 July 2026)
  • Develop a written AML/CTF Program approved by senior management before providing designated services
  • Conduct an ML/TF Risk Assessment covering customer types, service channels, and jurisdictions — and review it regularly
  • Perform Customer Due Diligence (CDD) — verify identities, screen for PEPs, and monitor ongoing relationships
  • Submit reports to AUSTRAC — Suspicious Matter Reports (SMR), Threshold Transaction Reports (TTR), and others
  • Maintain records for a minimum of 7 years, securely and retrievably
  • Train your staff before they commence relevant duties, with periodic refreshers
  • Arrange independent reviews of your AML/CTF program and remediate findings

Not sure if you're a reporting entity?

We offer a plain-language assessment to confirm your obligations and explain what steps you need to take.

Program Development

I want to develop an AML/CTF policy and procedure for my business

A compliant AML/CTF program is more than a document — it must reflect how your business actually operates. We help you build a practical, AUSTRAC-aligned program from the ground up.

1
ML/TF Risk Assessment
Identify and document the money laundering and terrorism financing risks specific to your customer types, products, service channels, and jurisdictions. This must be completed before your program is written.
2
Design Your AML/CTF Program
Develop a written program — approved by senior management — that addresses your risk profile. The program sets the framework; procedures translate it into daily operations.
3
Customer Due Diligence Procedures
Define how you verify identities, screen for politically exposed persons (PEPs), and conduct enhanced due diligence for high-risk customers. Procedures must cover all customer types you serve.
4
Reporting & Record-Keeping Framework
Establish clear processes for Suspicious Matter Reports, Threshold Transaction Reports, and International Funds Transfer Instructions — plus record retention procedures that meet the 7-year minimum.
5
Training & Governance
Implement staff vetting, AML/CTF training before duty commencement, periodic refreshers, and senior manager oversight — then schedule your independent review cycle.

Let us build your AML/CTF program

From risk assessment to final documentation — bespoke, AUSTRAC-aligned, and ready to implement.

What your AML/CTF program must include

Under section 26B of the AML/CTF Act, a compliant program must address all of the following:

Completed ML/TF risk assessment
Customer due diligence (CDD) procedures for all customer types
Ongoing customer monitoring processes
Sanctions screening procedures
Suspicious Matter Report (SMR) procedures
Threshold Transaction Report (TTR) procedures
Record-keeping policies (minimum 7 years)
Employee due diligence and background check procedures
AML/CTF training requirements and schedule
Senior management oversight and governance framework
Independent review and remediation plan

AUSTRAC's focus in enforcement: documented controls must match actual operational practices. A program that sits in a drawer — untested and untrained — is not a compliant program.

Independent Review

I want to review my current AML/CTF policy and procedures

An independent review is not just good practice — it's a legal obligation for reporting entities. We assess your existing program against current AUSTRAC expectations and flag gaps before a regulator does.

Program Gap Analysis

We benchmark your current documentation against the AML/CTF Act and AUSTRAC's guidance notes — identifying missing elements, outdated procedures, and areas of non-compliance.

CDD Procedure Review

We assess whether your customer due diligence procedures — including identity verification, beneficial ownership, PEP screening, and enhanced due diligence — meet current requirements.

Reporting Procedures Assessment

We check that your SMR, TTR, and IFTI obligations are clearly documented, consistently followed, and that staff understand what triggers a report and how to lodge one.

Operational Alignment Check

The highest-risk finding for AUSTRAC: documented controls that don't match how the business actually operates. We interview key staff and observe processes to identify this gap.

Ready for an independent review?

We'll deliver a written findings report with a prioritised remediation plan — ready to present to your board or senior management.

Our review process

How a review works

A structured, transparent process with clear deliverables at every stage.

Step 1 — Scoping
Initial consultation to understand your business, services, customer base, and existing documentation. We confirm scope and timeline.
Step 2 — Document Review
We review your AML/CTF program, risk assessment, CDD procedures, reporting logs, training records, and governance documentation.
Step 3 — Operational Assessment
We test whether documented controls are actually in use — interviewing staff and reviewing transaction samples where relevant.
Step 4 — Findings Report
A written report rating each control area against AUSTRAC's expectations, with prioritised remediation recommendations and suggested timelines.
Step 5 — Debrief & Support
We walk through the findings with your team and can assist with remediation — whether that means updating documents, retraining staff, or redesigning controls.
Compliance Software

Will I be compliant if I buy a compliance software?

Many Australian businesses assume that purchasing a compliance platform satisfies their AUSTRAC obligations. It does not. Software is a tool — compliance is a professional discipline that requires expert human judgement.

Software can do this
  • Flag transactions against rules and thresholds
  • Screen customer names against sanctions watchlists
  • Route cases through a defined workflow
  • Maintain audit trails and timestamped records
  • Track CDD document collection status
Software cannot do this
  • Draft or own your AML/CTF Program
  • Conduct your ML/TF risk assessment
  • Decide whether to file a Suspicious Matter Report
  • Provide an independent review of your own system
  • Accept liability — that always sits with you

Critical risk: template programs are non-compliant Many platforms auto-generate AML/CTF programs without analysing your actual business. AUSTRAC requires your program to reflect your specific size, nature, and risk profile. A generic template that hasn't been tailored by a professional does not satisfy the law — and carries the same enforcement exposure as having no program at all.

Want the full picture?

Read our in-depth guide: why AML software alone won't keep you compliant — and what a genuinely defensible program looks like.

Read the Full Guide
Our Approach

The Perfect Balance: Compliance Expertise + The Right Technology

We deliver the perfect balance of AML/CTF compliance expertise and AML/CTF compliance software. Every client's situation is different — and we design the right solution for your business, not a one-size-fits-all platform. Depending on your circumstances, your compliance framework may take any of these forms:

1
Fully Manual Procedures
For smaller entities where well-designed manual processes — registers, checklists, and decision logs — are proportionate and fully defensible.
2
Extending Your Existing Software
Build compliance functionality into your current CRM, practice management system, or ERP. No duplication. No data mismatches. No integration cost.
3
The AMLCo Compliance Platform
Our purpose-built platform with live DFAT sanctions screening, KYC management, alert queues, and AUSTRAC reporting — designed specifically for Australian reporting entities.
4
A Suitable Third-Party Platform
For larger or more complex entities, we specify, configure, and oversee the right established platform — without bias toward our own software.
We will not restrict you to our own software. Our obligation is to your compliance outcome — not our licensing revenue.
Explore the AMLCo Platform
Why The AML Consultant

Deep AML/CTF expertise. Practical advice.

We combine specialist AML/CTF knowledge with plain-language guidance — so your compliance program actually works in the real world, not just on paper.

Practical, Not Theoretical

We build compliance programs that work in the real world. We understand that a one-person accountancy practice has very different needs to a mid-size law firm — and we tailor our advice accordingly.

Regulator-Aligned Thinking

We know what AUSTRAC looks for in an enforcement context. Our reviews and programs are built to withstand scrutiny — because a compliant program shouldn't just look good, it should hold up.

AI-Enhanced Efficiency

We use AI tools to enhance the speed and depth of our analysis — but professional judgment underpins every recommendation. AI enhances efficiency; it does not replace expertise.

Accessible to All Businesses

From solo practitioners newly caught by Tranche 2 reforms to established financial services providers — we work with businesses of every size and complexity across all regulated sectors.

Clear, Actionable Deliverables

No vague recommendations. Every engagement produces written deliverables — programs, assessments, reports — that you can implement, present to your board, and rely on in a regulatory context.

Fixed-Scope Engagements

We quote clearly before we start. Whether it's a standalone review or full program development, you'll know exactly what you're getting and what it costs — no billing surprises.

Get in Touch

Contact Us

Whether you need a quick answer or want to discuss a full engagement, we're ready to help. Reach out by phone, email, or book a time directly below.

Phone & WhatsApp
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Book a time directly

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