AML/CTF independent reviews
AML/CTF Reviews by Australian AML Lawyers, Delivering Clear Findings, Practical Guidance & Board-Ready Reports Aligned with AUSTRAC & Your Risk Profile.
Anti-Money Laundering & Counter-Terrorism Financing (AML/CTF) Independent Review for your business
An AML/CTF independent review is impartial evaluation of your business’s AML / CTF program. Conducted by experienced our AML lawyers, it ensures your policies, procedures & controls comply with the AML/CTF Act 2006 & Part 8.6 of the AML/CTF Rules.
These reviews are essential for businesses to confirm that their AML/CTF programs are not only legally compliant but also effectively managing money laundering (ML), terrorism financing (TF), & proliferation financing (PF) risks. Each review produces a written report for your governing body, highlighting gaps, actionable recommendations & practical steps to strengthen your compliance framework.
With the AML/CTF Rules 2025, now in effect, completing an independent review demonstrates strong governance, regulatory accountability & readiness for AUSTRAC scrutiny. Timely evaluations also reduce the risk of civil penalties & provide confidence that your AML/CTF program is operating effectively.
What your AML/CTF independent evaluation covers
We assess the design & operation of your AML/CTF program across six key areas, so AUSTRAC can see how your controls work in practice.
01.AML/CTF program evaluation
Evaluating whether your AML/CTF program is current, risk‑based & aligned with the AML/CTF Act, Rules & AUSTRAC guidance.
02.ML/TF risk assessment review
Reviewing your business‑wide ML/TF risk assessment method & outputs to check they match your actual products, customers, channels & geographies.
03.KYC & customer due diligence (CDD) testing
Testing how your KYC, CDD & ECDD processes work in practice across onboarding, ongoing monitoring & higher‑risk customers, including file‑testing where appropriate.
04.Transaction monitoring program review
Assessing the design & effectiveness of your transaction monitoring rules, scenarios & alert handling to see whether suspicious activity would realistically be detected & escalated.
05.AML/CTF training review
Reviewing the scope, frequency & records of AML/CTF training to confirm staff understand their obligations & apply them in day‑to‑day operations.
06. AUSTRAC Reporting Obligations Review
Checking your SMR, TTR & IFTI reporting processes so the right matters are identified, reported on time & supported by clear records that meet your reporting obligations.
What Our AML/CTF Independent Reviews Cover
We assess the design & operation of your AML/CTF program across seven key areas, so AUSTRAC can see how your controls work in practice.
01.Risk Assessment Review
We examine your ML, TF & PF risk assessments to ensure they accurately identify, measure & mitigate the risks your business faces. This includes customer types, products, services, delivery channels, and geographic exposures.
02.Policy & Procedure Evaluation
Reviewing your business‑wide ML/TF risk assessment method & outputs to check they match your actual products, customers, channels & geographies.
03.KYC & Customer Due Diligence (CDD) Testing
Testing how your KYC, CDD & ECDD processes work in practice across onboarding, ongoing monitoring & higher‑risk customers, including file‑testing where appropriate.
04.Transaction Monitoring Program Review
Assessing the design & effectiveness of your transaction monitoring rules, scenarios & alert handling to see whether suspicious activity would realistically be detected & escalated.
05.AML/CTF training review
Reviewing the scope, frequency & records of AML/CTF training to confirm staff understand their obligations & apply them in day‑to‑day operations.
06.AUSTRAC Reporting Obligations Review
Checking your SMR, TTR & IFTI reporting processes so the right matters are identified, reported on time & supported by clear records that meet your reporting obligations.
07.Third Party & outsourced services providers
Our reviews cover third party & outsourced services providers including RegTech & reliance on third party transaction monitoring & reporting.
Who We Advise
We act for reporting entities operating in regulated, AML/CTF‑sensitive sectors. If you provide financial, credit, payment, digital asset or other designated services under the AML/CTF Act, we help you design, implement & independently evaluate programs that match your ML/TF 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 Independent Review
Our AML lawyers will contact you to discuss your situation & outline next steps.
Statutory Independent Evaluation / Review Packages
Each AML independent evaluation package is priced as a fixed-fee, one-off, project-based engagement.
Inclusions
Basic
Standard
Enhanced
Premium
Enterprise
$4,000 +GST
$8,000 +GST
$12,000 +GST
$16,000 +GST
$20,000 +GST
Review of AML/CTF Program documentation for currency & adequacy
Assessment of program operational effectiveness
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Testing transaction monitoring & SMRs, findings & recommendations
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Review of OCCD, findings & recommendations
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Testing against AUSTRAC sector‑specific risk assessments
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Additional operational testing of controls
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Board / executive reporting on review outcomes
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Support to implement agreed recommendations
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Tailored AML/CTF training session for staff or leaders
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Full Inclusions & Package Limits: View the full inclusions, scope and limits for each Independent AML/CTF Evaluation package in our Independent AML/CTF Evaluation Packages – Full Inclusions & Key Limits table here.
Terms: Prices are per package, exclusive of GST. At checkout, Stripe will display the GST‑inclusive total for the option you select. These online prices are designed for small to medium reporting entities that fit the assumptions and limits in the spec sheet. If your business is larger, more complex or you would 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. Your engagement is governed by our Terms & Conditions of Engagement.
Full Inclusions & Package Limits: View the full inclusions, scope and limits for each Independent AML/CTF Evaluation package in our Independent AML/CTF Evaluation Packages – Full Inclusions & Key Limits table here.
Terms: Prices are per package, exclusive of GST. At checkout, Stripe will display the GST‑inclusive total for the option you select. These online prices are designed for small to medium reporting entities that fit the assumptions and limits in the spec sheet. If your business is larger, more complex or you would 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. Your engagement is governed by our Terms & Conditions of Engagement.
Need help implementing your evaluation findings?
An AML/CTF independent evaluation only delivers value if the recommendations are actually implemented. Many clients use the evaluation as the starting point, then move into structured support to update their program, controls & documentation.
If you want help turning findings into concrete changes, our AML/CTF compliance subscriptions & Quick Start AML packages are designed to implement & maintain the improvements identified in your evaluation.
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 Independent Review
Our AML lawyers will contact you to discuss your situation & outline next steps.
How The Process Works
Step 1
Scope & Planning
We confirm the applicable AML/CTF obligations, your risk profile & the evaluation scope, then agree timelines, key contacts & information we’ll need.
Step 2
Review & Testing
We review your AML/CTF program, policies, registers & reporting, then sample‑test key controls against your risks & obligations.
Step 3
Draft Findings & Validation
We provide a draft evaluation report with targeted findings & practical fixes, then clarify any factual points so the final report reflects your operations.
Step 4
Final Report & Briefing
We issue the final independent evaluation report & brief senior management and/or your Board so actions, priorities & timeframes are clear.
Why choose us for AML/CTF independent Reviews
Lawyer‑led reviews
Every review is led by an experienced AML/CTF lawyer, so findings align with the AML/CTF laws.
Regulatory Depth & Practical Focus
We’ve worked inside banks & financial institutions, so findings focus on real ML/TF risk, not just theoretical checklists.
Clear, Fixed‑Fee Pricing
Scope & pricing are agreed up front with fixed‑fee review packages, so you know exactly what is covered without surprise time‑based bills.
Low Disruption & Fast Turnaround
We minimise pulls on your team, work from your existing documents & data, and deliver reports on agreed timelines.
Meet Your Legal Team
Discuss Your AML/CTF Independent Review
Our AML lawyers will contact you to discuss your situation & outline next steps.
AML Independent Review Essentials
AUSTRAC expectations for independent reviews
An AML/CTF independent review, also called an independent evaluation under the updated AML/CTF Rules 2025, must test whether your program is appropriately designed & operating effectively for your ML/TF/PF risks, not just whether it exists on paper. It should look at your ML/TF/PF risk assessment, program design & how key controls work in practice.
Our AML/CTF lawyers structure reviews to line up with AUSTRAC’s updated program & evaluation guidance.
Scope & frequency of evaluations
An independent review should cover governance, risk assessment, customer due diligence, monitoring, reporting, training & records, with scope tailored to your risk profile. Under the reforms, you must evaluate your program on a risk‑based cycle, generally at least every 3 years or more often for higher‑risk or fast‑changing businesses.
We help you document a review cycle that matches regulatory expectations & your business.
Evidence, documentation & remediation
Independent reviews must produce a written report setting out scope, testing, findings & recommendations, and Boards or senior managers are expected to receive and act on it.
We translate technical findings into clear documentation & remediation plans that your leadership & AUSTRAC can rely on, and help you evidence follow‑up actions.
Independence & conflicts of interest
The reviewer must be independent of the design & operation of your AML/CTF program, and have appropriate expertise. Engaging specialist AML/CTF lawyers who are not responsible for running your day‑to‑day program gives you a cleaner independence position if AUSTRAC ever questions the review.
We can also help you document how independence & conflicts were managed.
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 independent reviews
What is an independent review?
An AML/CTF independent review, also called an independent evaluation under the updated AML/CTF Rules 2025, is an impartial assessment of your AML/CTF Program. It checks whether your program is compliant, appropriate for your risk profile & operating effectively across your business.
What changed under the new AML/CTF Rules?
Yes, under the amended AML/CTF Act 2006 (Cth) reporting entities must arrange an independent evaluation of their AML/CTF program in addition to their own internal reviews. The obligation applies to all reporting entities, including those brought in under Tranche 2, with timing set out in the new Rules & AUSTRAC’s reform guidance.
What Does an Independent AML/CTF Review Cover?
You must conduct an independent evaluation at least every 3 years, with the exact frequency set having regard to the nature, size & complexity of your business. Higher‑risk or fast‑changing businesses may choose (or be expected) to evaluate more often. AUSTRAC’s transitional guidance also staggers first evaluation deadlines for newly regulated entities.
Who Can Conduct an Independent AML/CTF Review?
Your evaluator must be independent of the design & operation of your AML/CTF program, and have sufficient knowledge of AML/CTF obligations, your sector & ML/TF risks. AUSTRAC does not mandate specific qualifications, but expects evaluators to have relevant experience in AML/CTF compliance & evaluating the effectiveness of systems, controls, policies & procedures.
What Do Click Legal's AML/CTF Independent Reviews Cover?
Risk Assessment Review: We examine your ML, TF & PF risk assessments to ensure they accurately identify, measure & mitigate the risks your business faces. This includes customer types, products, services, delivery channels, and geographic exposures.
Policy & Procedure Evaluation: We assess the design & adequacy of your AML/CTF policies & procedures, confirming they are up-to-date, clear, and aligned with AUSTRAC expectations. This ensures staff have practical guidance to prevent and detect financial crime.
KYC & Customer Due Diligence (CDD) Testing: We test how your Know Your Customer (KYC), Customer Due Diligence (CDD) & Enhanced Customer Due Diligence (ECDD) processes work in practice across onboarding, ongoing monitoring, and higher-risk customers. Where appropriate, we conduct file-testing to confirm consistent application.
Transaction Monitoring Program Review: We assess the design & effectiveness of your transaction monitoring rules, scenarios & alert handling, confirming that suspicious activity is realistically detected and escalated.
AML/CTF Training Review: We review the scope, frequency & records of your AML/CTF training to ensure staff understand their obligations & consistently apply them in day-to-day operations.
AUSTRAC Reporting Obligations Review: We check your Suspicious Matter Reports (SMRs), transactions & AUSTRAC reporting.
Third Party & outsourced services providers: including RegTech & reliance on third party transaction monitoring & reporting.
What happens if the review identifies compliance issues?
If a review identifies gaps or weaknesses, you’re expected to address them through a remediation plan with clear owners & timeframes. AUSTRAC’s expectation is that you update your AML/CTF policies, procedures & risk assessment to reflect the findings, and be able to evidence both the review & your follow‑up actions.
How long does an independent review take?
Timeframes depend on the size & complexity of your business, the quality of your existing documentation & how quickly you can provide information, but most reviews run over several weeks rather than days. A well‑scoped engagement with clear access to systems, data & key staff will move significantly faster than a document‑only review.
Is the independent review report confidential?
The report itself is not automatically privileged, but engaging a law firm & structuring the work appropriately can support claims of legal professional privilege over parts of the review. You should discuss privilege & document handling at the outset so governance, Board reporting & regulatory expectations are all managed consciously.
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