AML/CTF Lawyers
We provide specialist AML/CTF legal & compliance support for reporting entities & Tranche 2 “gatekeeper” professions. From risk assessments & programs to independent evaluations, enforcement & remediation, we help you meet AUSTRAC expectations in practice.
AML/CTF legal & compliance support
We advise reporting entities & in‑scope Tranche 2 professions on the full lifecycle of AML/CTF obligations – from ML/TF/PF risk assessments & program design through to independent evaluations, AUSTRAC engagement & remediation.
Our AML/CTF lawyers combine technical regulatory expertise with practical implementation experience, so your frameworks are risk‑based, workable for your team & aligned with your compliance obligations under the AML/CTF Act.
Our AML/CTF Services
01. AML/CTF Independent Evaluations / Reviews
Evaluating the design & operation of your AML/CTF program & key controls so gaps are identified before AUSTRAC does.
02. AML/CTF Compliance Programs
Designing & updating risk‑based AML/CTF programs, policies & procedures that reflect your ML/TF/PF risk assessment & current Rules.
03. Outsourced AML/CTF legal & compliance counsel
Acting as your outsourced AML/CTF adviser or compliance officer to support transaction monitoring, AUSTRAC reporting & day‑to‑day program decisions.
04. AUSTRAC Enforcement & Remediation
Representing you in AUSTRAC enquiries, enforcement & remediation work, including responses, remediation plans & framework uplift to reduce penalty risk.
05. Tranche 2 Advisory & Readiness
Who We Advise
We advise reporting entities & in‑scope Tranche 2 professions that want specialist AML/CTF support, not generic compliance templates. If you provide financial, credit, payment, digital asset or other designated services – or will be captured as a gatekeeper – we help you design, run & evidence AML/CTF frameworks that match your risk.
AML/CTF clients we act for include:
Product providers
Advice providers
Credit providers
AFSL wholesale
Payments businesses
Carbon markets & renewables
Fintechs
Crypto, digital currency & virtual asset providers
Our Clients Include
Discuss Your AML/CTF Obligations
Our AML/CTF lawyers will contact you to discuss your situation & outline next steps.
How The Process Works
Step 1
Choose Your AML/CTF Engagement
We review your business model & legal obligations, then confirm whether you need ongoing compliance support, a statutory independent evaluation or both.
Step 2
Setup & Embed Compliance Support
We design or refine your AML/CTF program, risk assessment, KYC/CDD workflows & reporting so day‑to‑day operations match your risk profile & AUSTRAC expectations.
Step 3
Statutory Independent Evaluation/Review
We scope, test & report on your AML/CTF program under the independent evaluation/review requirements, then provide a clear report with practical remediation priorities.
Step 4
Implementation, Monitoring & Ongoing Counsel
We help you implement remediation, update policies & registers, train staff & stay on as outsourced AML/CTF counsel for monitoring, breach management & AUSTRAC liaison.
What Our Clients Say About Working With Us
Jason Gold
Managing Director, IT Pro Tech"At IT Pro Tech, we partner with businesses who share our commitment to integrity. Click Legal stands out in the legal space for exactly that. Hannah and the team impressed us with their deep understanding of compliance-heavy sectors and their ability to offer clear, practical legal advice without overcomplicating the process."
Guy Raven
Head of Surveillance Advisory, Westpac"Hannah demonstrated exceptional leadership and regulatory expertise. She played a pivotal role in developing the control room and establishing a strong regulatory compliance framework... Beyond her deep technical knowledge, Hannah is an outstanding mentor, approachable, and insightful."
Antonella Spatola
Founder, True To You Charity"Hannah at Click Legal has supported the board in establishing our documentation and legal framework to start on a solid footing. We appreciate her authentic interest in the charity's mission... We appreciate how she explains complex concepts in simple terms, avoiding legal jargon."
Sharon Yang
Head of Investment & Capital Mgmt"Hannah and Click Legal have provided reliable legal advice to us. It has been integral in helping us meet all our AFSL obligations with confidence. I highly recommend their services to any business needing compliance support."
Jason Watts GAICD
Managing Director, Neu Capital"Hannah blends rare regulatory expertise with sharp business acumen. As her Manager at Barclays, I watched her master APRA/ASIC frameworks and turn them into clear, actionable strategies... She's the kind of professional who simplifies complexity, and her integrity is unmatched."
Stuart Hill
Program Manager/Operations Manager"Hannah has exceptional depth of knowledge and expertise in building robust legal, risk, and compliance frameworks... Beyond her technical expertise, Hannah is a strategic thinker and a genuinely kind, friendly person who always supports and helps others."
Jason Lowry
Co-Founder, LPG"Could not recommend Click Legal more highly! Must have for start ups and small business owners looking to trust someone to help set up your business right!"
Jason Gold
Managing Director, IT Pro Tech"At IT Pro Tech, we partner with businesses who share our commitment to integrity. Click Legal stands out in the legal space for exactly that. Hannah and the team impressed us with their deep understanding of compliance-heavy sectors and their ability to offer clear, practical legal advice without overcomplicating the process."
Guy Raven
Head of Surveillance Advisory, Westpac"Hannah demonstrated exceptional leadership and regulatory expertise. She played a pivotal role in developing the control room and establishing a strong regulatory compliance framework... Beyond her deep technical knowledge, Hannah is an outstanding mentor, approachable, and insightful."
Antonella Spatola
Founder, True To You Charity"Hannah at Click Legal has supported the board in establishing our documentation and legal framework to start on a solid footing. We appreciate her authentic interest in the charity's mission... We appreciate how she explains complex concepts in simple terms, avoiding legal jargon."
Sharon Yang
Head of Investment & Capital Mgmt"Hannah and Click Legal have provided reliable legal advice to us. It has been integral in helping us meet all our AFSL obligations with confidence. I highly recommend their services to any business needing compliance support."
Jason Watts GAICD
Managing Director, Neu Capital"Hannah blends rare regulatory expertise with sharp business acumen. As her Manager at Barclays, I watched her master APRA/ASIC frameworks and turn them into clear, actionable strategies... She's the kind of professional who simplifies complexity, and her integrity is unmatched."
Stuart Hill
Program Manager/Operations Manager"Hannah has exceptional depth of knowledge and expertise in building robust legal, risk, and compliance frameworks... Beyond her technical expertise, Hannah is a strategic thinker and a genuinely kind, friendly person who always supports and helps others."
Jason Lowry
Co-Founder, LPG"Could not recommend Click Legal more highly! Must have for start ups and small business owners looking to trust someone to help set up your business right!"
Discuss Your AML/CTF Obligations
Our AML/CTF lawyers will contact you to discuss your situation & outline next steps.
Why Choose Click Legal For AML/CTF
Lawyer-Led Legal Privilege
Your sensitive internal investigations & compliance findings are protected by legal professional privilege.
Transparent Fixed Fees
We scope every engagement on a 100% fixed-fee basis for total cost certainty.
Operational In-House Experience
Our team uses real-world banking experience to ensure risk management is practical & operationally viable.
Outsourced Compliance Capability
We manage your AUSTRAC reporting obligations & day-to-day controls as a fully outsourced compliance function.
Meet Your Legal Team
Discuss Your AML / CTF Obligations
Our AML/CTF lawyers will contact you to discuss your situation & outline next steps.
AML/CTF Compliance Essentials
The Independent Requirement
AUSTRAC expects independent evaluations or reviews to be conducted by someone who is genuinely independent of the design, implementation & day‑to‑day operation of your AML/CTF program. Internal staff with AML/CTF responsibilities often fail this test.
Engaging AML/CTF lawyers who are not part of your internal compliance function can help you demonstrate independence & defend the work if AUSTRAC ever scrutinises it.
Tranche 2 Reforms
Tranche 2 reforms extend AML/CTF obligations to “gatekeeper” professions, including certain lawyers, accountants, real estate professionals & trust/company service providers. These changes are aimed at professionals who facilitate high‑value or higher‑risk transactions.
We help Tranche 2 entities assess whether they are in‑scope, and prepare ML/TF/PF risk assessments, AML/CTF programs & controls well before the 1 July 2026 deadline.
Director & Board oversight
Boards & directors can face significant consequences where there are systemic AML/CTF failures, particularly if governance, oversight or resourcing have been weak. AUSTRAC expects active Board‑level engagement with ML/TF/PF risk, program effectiveness & reporting quality.
Specialist legal advice helps directors & senior management demonstrate the steps they took, and document governance in a way that stands up during an investigation.
Designated services & reporting entity status
You must enrol with AUSTRAC if you provide one or more designated services under the AML/CTF Act. This covers specific financial, remittance, gambling, digital currency exchange & other activities with an Australian link, and will soon include certain “gatekeeper” services under Tranche 2.
We review your business model to confirm whether you are a reporting entity, which designated services you provide & exactly which AML/CTF obligations apply.
AML/CTF Compliance Templates For Reporting Entities
Practical templates to manage AFSL compliance obligations, AML/CTF settings & core governance policies.
Legal & Compliance Insights
Frequently Asked Questions About AML/CTF
Do I need to enrol with AUSTRAC?
You must enrol with AUSTRAC if your organisation provides one or more “designated services” under the AML/CTF Act. This currently covers many financial services, remittance & gambling businesses, and from 1 July 2026 will extend to certain lawyers, accountants, real estate professionals & trust/company service providers. If you are unsure whether your services qualify, it’s worth getting advice before you start offering them.
What is the difference between Part A & Part B of an AML/CTF program?
Part A deals with your overall risk‑based systems & controls – governance, ML/TF/PF risk assessment, monitoring, reporting, training & record‑keeping. Part B focuses on customer due diligence – how you identify, verify & monitor customers and apply CDD/ECDD in practice. Together, both parts form the AML/CTF program AUSTRAC expects you to have and keep up to date.
How often must our AML/CTF framework be reviewed?
You need to keep your AML/CTF program current through regular internal reviews and, under the reforms, periodic independent evaluations by a suitably qualified & independent person. The exact frequency should reflect the nature, size & complexity of your business, but most entities should expect a formal review or evaluation at least every few years or after major changes. Higher‑risk or fast‑changing businesses often choose to do this more frequently.
Can a consultant do the AML INdependent review or evaluation, or should we use a lawyer?
A consultant can conduct an independent evaluation if they’re genuinely independent and have the right expertise, but using a law firm can add legal professional privilege over parts of the work if it’s structured correctly. That can give you more room to identify & fix issues internally before engaging with AUSTRAC. The key is getting both independence & competence right, whoever you appoint.
What happens if we breach AML/CTF laws?
Breaches can lead to civil penalty proceedings, enforceable undertakings, remedial directions & in serious or systemic cases multi‑million‑dollar penalties and intense regulatory scrutiny. AUSTRAC also publishes enforcement outcomes, so there is real reputational risk as well. If you suspect a breach, you should get advice early so investigations, remediation & engagement with AUSTRAC are managed carefully.
How much does an AML/CTF program or evaluation cost?
Costs depend on your size, number of designated services, customer types, channels & how mature your current framework is. Most firms will scope the work upfront and offer fixed‑fee or tiered packages so you know what is covered before you commit. In practice, the cost of getting it wrong is almost always higher than the cost of building a solid framework.
What are the Tranche 2 reforms & who do they affect?
Tranche 2 extends AML/CTF obligations to “gatekeeper” professions such as certain lawyers, accountants, real estate professionals & trust/company service providers. In‑scope practices will need to determine if they are reporting entities, enrol with AUSTRAC, implement risk‑based AML/CTF programs & be ready to report suspicious matters before 1 July 2026. If you’re in these sectors, it’s better to start early than rush at the deadline.
Do you provide AML/CTF staff training?
Yes, we deliver targeted AML/CTF training to boards, senior management & frontline staff so they understand their obligations and recognise ML/TF/PF risk in day‑to‑day work. Training is usually built around your own risk assessment & program, not generic slides, so it actually supports your framework rather than sitting on the shelf.
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