AML/CTF Compliance Programs
We design AML/CTF programs, risk assessments & workflows for reporting entities so they satisfy AML/CTF laws in practice, not just on paper.
Our AML/CTF lawyers tailor frameworks to your products, channels & customer risk, with clear board‑level oversight built in.
Our AML/CTF compliance services
We design, implement & maintain AML/CTF programs for reporting entities so they match your ML/TF risk profile & AML/CTF legal requirements. Our AML/CTF lawyers help you build practical frameworks that your team can actually run day‑to‑day, then keep them current as your business & the law change.
Our services includes:
01. ML/TF Risk Assessments
Mapping your customers, products, channels & jurisdictions to document specific ML/TF risks & set a clear risk appetite for your AML/CTF program.
02. AML/CTF Program Design (Part A & Part B)
Designing or updating your Part A & Part B program so it is risk‑based, tailored to your business model & aligned with the AML/CTF Act, Rules & AUSTRAC guidance.
03. Program Implementation & Staff Training
Implementing your AML/CTF program in practice by configuring obligations registers & workflows, then delivering role‑specific training so staff understand & apply their obligations.
04. Outsourced AML Compliance Counsel Support
Providing ongoing support as your outsourced AML/CTF adviser or compliance officer, including guidance on unusual or suspicious activity, reporting questions & day‑to‑day program operation.
05. Ongoing Program Maintenance & Reviews
Keeping your AML/CTF framework up to date with legislative changes, AUSTRAC guidance & shifts in your business, and conducting internal effectiveness reviews to identify gaps before they become issues.
Who We Advise
We work with reporting entities that need practical AML/CTF programs they can run day‑to‑day, not just documents for a shelf. If you provide financial, credit, payment, digital asset or other designated services under the AML/CTF Act, we help you design, implement & maintain frameworks that match your ML/TF risk.
AML/CTF compliance 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 Compliance Program
Our AML/CTF lawyers will contact you to discuss your situation & outline next steps.
AML / CTF Compliance Plans
Inclusions
Basic
Standard
Enhanced
Premium
Enterprise
$1,000/mo. +GST
$2,000/mo. +GST
$4,000/mo. +GST
$5,000/mo. +GST
$7,000/mo. +GST
Core AML/CTF Program tailored to your business (incl. ML/TF risk assessment)
Hands‑on implementation support (onsite or online)
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Procedures & templates (CDD, TMP & SMR)
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Standard AML/CTF staff training
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Customer identification & compliance sign‑off
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Quarterly compliance check‑ins
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Annual AML/CTF compliance report for AUSTRAC
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Tailored AML training for staff
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Regulator update briefings
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Dedicated support line for ad‑hoc advice
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Additional legal & compliance documentation
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Ongoing strategic AML/CTF advisory & consultation
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Remediation support & project work
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Regulator engagement assistance
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Full Inclusions & Plan Limits: View the full inclusions, frequency, limits and minimum term for each AML/CTF Compliance plan in our AML/CTF Compliance Plans – Full Inclusions & Key Limits table here.
Terms: Prices are per month, exclusive of GST. At checkout, Stripe will display the GST‑inclusive total (for example, $7,000 + GST = $7,700 per month). These online prices are for small to medium businesses that fit the assumptions and limits in the spec sheet. If your business is larger, more complex or you’d like a tailored quote, please contact us before purchasing. If, after purchase, we determine that your business is outside scope, we may offer a revised custom quote or a full refund before work begins. A minimum initial term of six (6) months applies to all AML/CTF Compliance subscription and retainer plans. Your engagement is governed by our Terms & Conditions of Engagement.
Full Inclusions & Plan Limits: View the full inclusions, frequency, limits and minimum term for each AML/CTF Compliance plan in our AML/CTF Compliance Plans – Full Inclusions & Key Limits table here.
Terms: Prices are per month, exclusive of GST. At checkout, Stripe will display the GST‑inclusive total (for example, $7,000 + GST = $7,700 per month). These online prices are for small to medium businesses that fit the assumptions and limits in the spec sheet. If your business is larger, more complex or you’d like a tailored quote, please contact us before purchasing. If, after purchase, we determine that your business is outside scope, we may offer a revised custom quote or a full refund before work begins. A minimum initial term of six (6) months applies to all AML/CTF Compliance subscription and retainer plans. Your engagement is governed by our Terms & Conditions of Engagement.
Quick‑Start AML Packages
Not Ready For A Full AML Plan Yet?
Risk Assessment & AML Program
$3,995 + GST
Our Risk Assessment and AML Program drafting service provides tailored compliance documentation aligned with AML/CTF legal requirements so your business can properly manage and mitigate money laundering and terrorism financing risks.
This comprehensive package includes:
- Customised AML/CTF Program
- Business Risk Assessment
- Ongoing compliance checklists
- Staff guidance documents
AML as a Service
$399/m + GST
Outsource your day‑to‑day AML compliance tasks to Click Legal so you can focus on running the business. This is a stress‑free, lower‑cost way to stay AML compliant without hiring permanent staff.
For businesses with up to 50 new customers per annum.
What’s included:
- KYC onboarding of new customers (individuals and businesses)
- Screening against watchlists for PEP, sanctions and adverse media
- Transaction monitoring alongside customer due diligence
- Ongoing compliance support
- Quarterly reporting
AML Staff by the Hour – 8hr Pack
$995 + GST
Get short‑term specialist AML help without hiring full‑time staff. Our AML lawyers and compliance specialists work remotely to your office so you get experienced support exactly when you need it.
Best for:
- KYC onboarding
- Periodic reviews and light‑touch remediation projects
- Transaction monitoring reviews
- Enhanced Due Diligence (EDD) support
- Assistance during audits or regulatory submissions
- Covering staff leave or peak periods
- Drafting or updating discrete AML policies and procedures
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 Compliance Program
Our AML/CTF lawyers will contact you to discuss your situation & outline next steps.
How The Process Works
Step 1
Discovery & Risk Assessment
We map your products & channels to document the specific money laundering & terrorism financing risks your business must manage.
Step 2
Program Design & Documentation
We draft bespoke Part A & Part B documentation that aligns with your risk assessment & meets your anti-money laundering and counter-terrorism financing obligations.
Step 3
Implementation & Training
We configure your obligations register & deliver practical training so your compliance officer & staff can confidently apply the framework.
Step 4
Ongoing Support & Compliance Plans
We provide regular updates & support for suspicious matters to ensure your program remains current with evolving legislation.
Why Choose Click Legal For AML/CTF Compliance
Lawyer‑Led AML/CTF Programs
Specialist financial services lawyers design your framework to align with the AML/CTF for consistent, risk‑based decision‑making.
Fully Tailored, Not Template‑Based
We build bespoke programs based on your specific ML/TF risk assessment to reflect your actual products, customers & delivery channels.
End‑To‑End Implementation
Our team configures your obligations register & workflows to embed compliance into daily operations for your staff & compliance officer.
Outsourced Compliance Function
Subscription plans provide an external compliance function to manage ongoing maintenance, reporting & independent reviews as your business evolves.
Meet Your Legal Team
Discuss Your AML/CTF Compliance Program
Our AML/CTF lawyers will contact you to discuss your situation & outline next steps.
Core AML/CTF program concepts
Part A vs Part B Programs
Part A covers general risk management systems & controls. Part B details customer identification & verification procedures.
Both parts must align with your specific ML/TF risks. Our AML compliance lawyers ensure your documentation meets strict AML/CTF legal requirements.
The Risk Assessment Requirement
A documented ML/TF risk assessment is the legal foundation of your program. It identifies specific money laundering & terrorism financing risks you face.
Generic templates often fail this critical step. Our experienced AML lawyers help you map risks accurately so your framework is properly tailored to your risk profile & compliance obligations.
Tranche 2 Reforms
Reforms will soon extend AML/CTF rules to lawyers, accountants & real estate agents. These “Tranche 2” entities must prepare for strict new obligations.
Early preparation prevents compliance panic later. Our specialise AML compliance lawyers help you assess your future liability now.
Designated Business Groups
Related entities may form a Designated Business Group (DBG) to share compliance duties. This allows members to rely on a common program & risk assessment.
Structuring a DBG correctly reduces administrative burden. We advise on the most efficient structure for your corporate group.
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 Compliance
What is an AML/CTF Program?
An AML/CTF program is the documented framework a reporting entity must have to identify, mitigate & manage money laundering, terrorism financing & (now) proliferation financing risks. It sets out your governance, ML/TF/PF risk assessment, controls, customer due diligence, monitoring, reporting & record‑keeping arrangements. You must have an effective AML/CTF program in place before you start providing any designated services.
Who needs to have an AML/CTF Program?
Any business that provides one or more “designated services” with a geographical link to Australia is a reporting entity & must have an AML/CTF program. This currently includes banks, lenders, remittance providers, casinos, bullion dealers, digital currency exchanges & other financial services businesses, and from 1 July 2026 will extend to certain lawyers, accountants, real estate professionals & trust/company service providers under the Tranche 2 reforms.
Can we use an off‑the‑shelf template for our AML/CTF program?
You can use templates as a starting point, but they are not sufficient on their own because your program must be based on your own ML/TF/PF risk assessment. AUSTRAC expects your program to reflect your actual customers, services, delivery channels, jurisdictions & data, not boilerplate wording. A compliant framework almost always requires tailoring beyond a generic document.
What is the difference between Part A & Part B of an AML/CTF program?
Part A covers your overall risk‑based systems & controls – governance, ML/TF/PF risk assessment, monitoring, reporting, training & record‑keeping. Part B focuses on your customer due diligence – how you identify, verify & monitor different customer types and apply CDD/ECDD. Most reporting entities must have both parts documented & operating in practice.
How often must an AML/CTF program be reviewed or evaluated?
Your program must be kept up to date through regular internal reviews and, under the reforms, periodic independent evaluations by a suitably qualified & independent person. Frequency must be risk‑based, taking into account the nature, size & complexity of your business, but AUSTRAC’s emerging expectation is that ML/TF/PF risk assessments and program effectiveness are formally reviewed at least every 3 years or when there are significant changes.
Do we need to appoint an AML/CTF compliance officer?
Yes, it is now an explicit requirement to appoint a fit & proper AML/CTF compliance officer at management level who is responsible for implementing & overseeing the AML/CTF program. This must be documented in your program and AUSTRAC expects you to be able to show how that person is empowered and resourced to perform the role.
What are the penalties for not complying with AML/CTF obligations?
Non‑compliance can lead to civil penalty proceedings, enforceable undertakings, remedial directions & in serious or systemic cases multi‑million dollar fines and intense regulatory scrutiny. AUSTRAC regularly takes public enforcement action where entities fail to maintain adequate programs, risk assessments, reporting or customer due diligence. Beyond financial penalties, there is also significant reputational & relationship damage with regulators, banks & counterparties.
What is a ML/TF/PF risk assessment?
A ML/TF/PF risk assessment is the structured process of identifying & documenting your exposure to money laundering, terrorism financing & proliferation financing risk based on your customers, services, channels, jurisdictions & AUSTRAC risk communications. Under the amended AML/CTF Act, you must conduct this assessment before providing designated services and keep it updated when risks or your business change, at least every 3 years. It is the foundation for designing a risk‑based AML/CTF program.
Do we need to enrol or register with AUSTRAC?
Yes, reporting entities must enrol with AUSTRAC before providing any designated services, and some sectors such as remittance providers & digital currency exchanges must also register specific services. For Tranche 2 professions, the government expects that by 1 July 2026 in‑scope practices will have determined if they are reporting entities, enrolled with AUSTRAC, implemented an AML/CTF program & be ready to report suspicious matters.
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