Inclusions | Basic $4,000 (One-Off) | Standard $8,000 (One-Off) | Enhanced $12,000 (One-Off) | Premium $16,000 (One-Off) | Enterprise $20,000 (One-Off) | What This Includes (Plain English, Frequency & Limits) |
Review Of AML/CTF Program Documentation For Currency & Adequacy | ✔️ | ✔️ | ✔️ | ✔️ | ✔️ | - We conduct a technical audit of your AML/CTF Program and ML/TF/PF Risk Assessment to ensure they meet all specific legislative requirements under the AML/CTF Act and Rules. We check if your documents are up-to-date and contain all mandatory components.
- Included: Review of up to 4 core documents. Includes a compliance gap table.
- Frequency: One-off (single engagement).
- Caps: Document review only (no testing of implementation). Does not include rewriting.
- Out of Scope: Drafting/rewriting documents (quoted separately).
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Assessment Of Program Operational Effectiveness | – | ✔️ | ✔️ | ✔️ | ✔️ | - We go beyond the documents to test if your program actually works in practice. This includes interviews with key personnel (AML CTF Compliance Officer, compliance staff) and process walkthroughs to see if procedures are understood and followed.
- Included: Up to 4 staff interviews (30-45 mins each) and observation of key processes.
- Frequency: One-off (single engagement).
- Caps: Up to 4 interviews. Additional interviews are $300/hr.
- Out of Scope: File or transaction testing (see below).
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Testing transaction monitoring and SMRs, findings and recommendations | – | – | ✔️ | ✔️ | ✔️ | - We test your transaction monitoring systems and Suspicious Matter Reporting (SMRs) processes. We check if alerts are triggered correctly, investigated properly, and if SMRs are filed accurately and on time.
- Included: Review of up to 8 transaction monitoring alerts and 3 drafted SMRs (anonymised). Includes findings and recommendations.
- Frequency: One-off (single engagement).
- Caps: 8 alerts + 3 SMRs. Testing of automated system logic is extra.
- Out of Scope: Backlog remediation or correcting past SMRs.
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Review Of Ongoing Customer Due Diligence, findings and recommendations | – | – | – | ✔️ | ✔️ | - We sample your actual customer files to verify that your team is conducting KYC correctly, performing ongoing CDD updates, and screening for PEPs/sanctions as required by Part B of your program.
- Included: Review of up to 25 customer files (KYC/CDD/ECDD). Includes findings and recommendations.
- Frequency: One-off (single engagement).
- Caps: 25 files. Files requiring complex beneficial ownership tracing (>2 layers) are extra.
- Out of Scope: Fixing deficient files (remediation).
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Testing Against AUSTRAC Sector-Specific Risk Assessment | – | – | – | – | ✔️ | - We benchmark your AML/CTF controls against AUSTRAC’s latest sector-specific guidance for your industry to identify gaps or emerging risks you may have missed. Ensures your program is aligned with your current risk profile.
- Included: Comparative analysis against up to 2 sector risk assessments.
- Frequency: One-off (single engagement).
- Caps: 2 sectors. Multi-sector analysis beyond 2 quoted separately.
- Out of Scope: Updating your risk assessment.
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Additional Operational Testing Of Controls | – | – | – | – | ✔️ | - We test broader AML/CTF controls beyond files and transactions, such as your staff training records, third-party due diligence, or IT access logs to ensure the overall control environment is sound.
- Included: Testing of up to 4 additional control types (e.g., training records, third-party DD, IT access, governance documentation).
- Frequency: One-off (single engagement).
- Caps: 4 control types. IT security audits are separate.
- Out of Scope: Penetration testing or technical IT audits.
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Board / Executive Reporting On Review Outcomes | – | – | – | – | ✔️ | - We draft a formal Independent Evaluation Report (compliant with the updated AML/CTF Rules) suitable for presentation to your Board or to AUSTRAC. Includes executive summary, detailed findings, and actionable recommendations.
- Included: Drafting of a formal report (up to 20 pages). One round of amendments.
- Frequency: One-off (delivered at end of evaluation).
- Caps: Two rounds of amendments. Attending the Board meeting to present is extra ($400/hr).
- Out of Scope: Presenting to the Board (quoted separately).
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Support To Implement Agreed Recommendations | – | – | – | – | ✔️ | - After delivering the report, we help you on how to implement the recommendations—such as recommendations on how to overcome deficient procedures, or advice on SMRs, to ensure ongoing effectiveness.
- Included: Up to 2 hours of advisory support.
- Frequency: One-off (post-evaluation).
- Caps: 2 hours included. Major remediation projects (e.g., 10+ files) are scoped separately.
- Out of Scope: Large-scale remediation projects.
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Tailored AML/CTF Training Session For Staff or Leaders | – | – | – | – | ✔️ | - Based on the specific gaps identified during the evaluation, we deliver a one-off training session to your staff or leadership team to address those weaknesses directly and improve overall effectiveness.
- Included: Design and delivery of one 90-minute virtual training session.
- Frequency: One-off (post-evaluation).
- Caps: Up to 30 attendees. Additional sessions or onsite delivery (travel extra) quoted separately.
- Out of Scope: General AML training (not linked to evaluation findings).
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