Fractional AML/CTF Compliance Officer Services
We act as your senior AML/CTF compliance partner for reporting entities with AML/CTF obligations under the AML/CTF Act & Rules – without the cost of a full-time officer.
Your Fractional AML/CTF Compliance Officer
Click Legal is a specialist Australian law firm. We take ownership of your AML/CTF program so you can focus on running the business. As your fractional AML/CTF Compliance Officer, we step into the senior role AUSTRAC expects to see – without the cost of a full-time executive hire.
We support you across the full AML/CTF lifecycle: ML/TF/PF risk assessments, program design, KYC/CDD, monitoring, AUSTRAC reporting, independent reviews & remediation. You get senior AML leadership aligned with the AML/CTF Act, Rules 2025 & AUSTRAC guidance on a fixed-fee basis.
What We Do As Your Fractional AML/CTF Compliance Officer
As your AML/CTF Compliance Officer, we provide ongoing oversight & execution support tailored to your products, customers & channels. We combine program design, control monitoring & reporting oversight so your AML/CTF framework is both compliant & workable for your team.
01. AML/CTF Program & ML/TF/PF Risk Assessment
We oversee the design & upkeep of your AML/CTF program & risk assessment, by:
- keeping Part A & Part B current, risk-based & aligned with the Act, Rules 2025 & AUSTRAC guidance;
- ensuring your ML/TF/PF risk assessment reflects real products, customers, channels & geographies;
- documenting updates so independent reviewers & AUSTRAC can follow the logic.
02. KYC, CDD & ECDD Monitoring
We make sure customer due diligence settings work in practice, by:
- overseeing KYC/CDD/ECDD workflows across onboarding, ongoing monitoring & higher-risk customers;
- sampling real files to test how policies are applied day-to-day;
- closing gaps where procedures, systems or staff behaviour diverge from your AML/CTF program.
03. Transaction Monitoring & AUSTRAC Reporting
We oversee how suspicious activity is detected, escalated & reported, by:
- reviewing transaction monitoring rules, alerts & case handling for effectiveness;
- overseeing SMR, TTR & IFTI identification, escalation & timely lodgement;
- aligning monitoring & reporting with your risk assessment & AUSTRAC’s expectations.
04. Governance, Board Reporting & Independent Reviews
We connect AML/CTF operations with your governance & review cycle, by:
- preparing AML/CTF reports for boards & committees with clear status, issues & actions;
- coordinating independent evaluations/reviews & management responses to findings;
- maintaining evidence (minutes, packs, action logs) that stands up if AUSTRAC asks questions.
05. Training, Third Parties & Continuous Improvement
We help your AML/CTF framework evolve with your business & providers, by:
- designing & overseeing AML/CTF training so staff understand & apply obligations;
- managing AML/CTF aspects of third-party, RegTech & reliance arrangements;
- keeping a simple improvement backlog from incidents, reviews & new AUSTRAC guidance, & helping you work through it over time.
Who We Advise
We act for reporting entities that need a named AML/CTF Compliance Officer who truly understands AUSTRAC expectations & ML/TF/PF risk – not just a policy on paper. If you provide financial, credit, payment, digital asset or other designated services & want senior AML leadership without a full-time hire, a fractional AML/CTF Compliance Officer is a fit.
AML/CTF clients we act for include:
Product & fund providers
Wealth & advice licensees
Credit providers & non-bank lenders
Wholesale & AFSL fund managers
Payments & remittance businesses
Carbon markets, ESG & renewables
Fintechs & embedded finance platforms
Crypto, digital currency & virtual asset providers
Our Clients Include
Discuss Your Fractional AML/CTF Compliance Officer Needs
Our senior AML/CTF lawyers will contact you to discuss your program, ML/TF/PF risk & AUSTRAC obligations & outline clear next steps.
Fractional AML/CTF Compliance Officer in Our FGC Plans
Our Fractional AML/CTF Compliance Officer role is usually delivered as part of our Fractional General Counsel subscription, often alongside broader Compliance Officer support. The plans below show typical tiers; we confirm the right tier & AML/CTF scope based on your services, risk profile & compliance workload.
Inclusions
Basic
Standard
Enhanced
Premium
Enterprise
$2,000/mo. +GST
$4,000/mo. +GST
$6,000/mo. +GST
$8,000/mo. +GST
$10,000/mo. +GST
Core legal & compliance documents tailored to your business
Hands‑on implementation support (onsite or online)
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Compliance registers and templates
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Compliance reporting support
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Standard staff training
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Annual review of documents and frameworks
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Quarterly compliance updates
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Monthly strategy or consultation session
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Tailored training for staff
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Regulator & industry 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 legal 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 plan in our Fractional General Counsel – Inclusions & Key Limits table here.
Terms: Prices are per month, exclusive of GST. At checkout, Stripe will display the GST‑inclusive total (for example, $10,000 + GST = $11,000 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 Fractional General Counsel 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 plan in our Fractional General Counsel – Inclusions & Key Limits table here.
Terms: Prices are per month, exclusive of GST. At checkout, Stripe will display the GST‑inclusive total (for example, $10,000 + GST = $11,000 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 Fractional General Counsel plans. Your engagement is governed by our Terms & Conditions of Engagement.
Featured By Digital Reference (2025)
“Best Fractional General Counsel Services In Australia”
Featuring Click Legal founder, Hannah Deuk, as a “Founder To Watch In 2025”.
What Our Clients Say About Working With Us
GUY RAVEN
Head of Surveillance Advisory, Westpac
JASON WATTS
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.”
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.”
Freshta Mayar
Google Verified Review
“A fantastic team, very easy to work with and provide great service and advice. Hannah and her team are absolute superstars – commercial, knowledgeable and efficient.”
Shu Jen & James Benson
Asset Management
“Handled the legal admin we avoided—contracts, policies, the lot—so we could focus on growing the business.”
David Parker
Founder of Innovate Solutions Pty Ltd
“After experiencing poor advice from other lawyers, I was fortunate to connect with Hannah. She stands out with her expertise, intelligence, and entrepreneurial mindset. Hannah’s ability to navigate complex legal matters and provide actionable guidance for startups and scaling businesses is unmatched. Highly recommend her services.”
Emma Reid
Freelancer Graphic Designer
Eran Ben-Shahar
CTO, Product, Strategy, Technology | SSPG Founder
Hillier Deniz
CEO, Paragon Funds Management
Erin Sutton
Business Unit Leader
Andrew Lane
Founder Shoplab
“Startups, meet your legal dream team Click Legal. They speak your language, understand scaling businesses, and deliver founder-friendly advice that fits your growth.”
Sunita
Verified Review
Discuss Your Fractional AML/CTF Compliance Officer Needs
Our senior AML/CTF lawyers will contact you to discuss your program, ML/TF/PF risk & AUSTRAC obligations & outline clear next steps.
How The Process Works
Step 1
AML/CTF Scope & Gap Review
We confirm which designated services you provide, how your current AML/CTF program & risk assessment are set up, & where the AML/CTF Compliance Officer function is stretched or missing.
Step 2
Program & Risk Assessment Uplift Plan
We map your ML/TF/PF risks, program settings & controls, then design or refresh your AML/CTF program & risk assessment so they match the Rules 2025 & AUSTRAC guidance.
Step 3
Onboarding As Your AML/CTF Compliance Officer
We become your AML/CTF Compliance Officer, access your systems, set up or refresh key registers & reporting templates, & agree how we’ll liaise with management, boards & AUSTRAC.
Step 4
Ongoing AML/CTF Operations & Reporting
We oversee KYC/CDD, monitoring & AUSTRAC reporting, keep an eye on incidents & remediation, & prepare regular AML/CTF updates so your governance & evidence stay in shape.
Step 5
Review & Adjust With Reforms & Reviews
We adjust scope & focus as new products launch, AML/CTF reforms evolve or independent reviews identify new priorities, so your AML/CTF framework stays aligned with your actual risk.
Why Choose Click Legal As Your Fractional AML/CTF Compliance Officer
Lawyer-Led AML/CTF Leadership
Your AML/CTF Compliance Officer is an experienced AML lawyer with deep financial services & AUSTRAC experience, not a generic consultant learning the regime on the job.
AUSTRAC-Ready Frameworks & Evidence
We design programs, risk assessments, registers & reports so AUSTRAC & independent reviewers can clearly see how your obligations are met & how issues are managed over time.
Senior AML Officer Capability On A Fixed-Fee Basis
You access senior AML/CTF Compliance Officer capability on a predictable subscription instead of carrying a full-time executive salary, bonus & overhead.
Integrated With Reviews & Governance
We already conduct statutory independent evaluations & support AFSL/ACL compliance & board reporting, so your AML/CTF officer function is fully integrated into your wider governance, not bolted on.
Meet Your Legal Team
Discuss Your Fractional AML/CTF Compliance Officer Needs
Our senior AML/CTF lawyers will contact you to discuss your program, ML/TF/PF risk & AUSTRAC obligations & outline clear next steps.
How Fractional AML/CTF Compliance Officer Support Works
Fractional vs In-House AML/CTF Compliance Officer
A full-time AML/CTF Compliance Officer adds permanent headcount, salary & HR overhead. A fractional model gives you senior AML leadership on a fixed-fee basis, sized to your current risk profile & program maturity.
When To Appoint A Fractional AML/CTF Officer
You may not need a full internal AML team, but once you are a reporting entity with real ML/TF/PF risk, new products or AUSTRAC attention, you need clear, senior ownership of your program. We step in when the program exists on paper but no one is properly accountable for how it actually runs.
Independence, Reviews & The Officer Role
Independent evaluations & reviews test design & operation, but they do not run your AML/CTF program day-to-day. A fractional AML/CTF Compliance Officer owns implementation & follow-through on findings while remaining distinct from routine processing.
Framework, Evidence & AUSTRAC Engagement
AUSTRAC wants more than a Part A/Part B binder – it wants risk assessments, controls & evidence that monitoring, reporting & remediation really happen. We join the dots between your program, registers, alerts, SMRs/TTRs & board reporting so your AML/CTF story is clear if AUSTRAC ever asks.
Compliance & Regulatory Insights
Ready-to-Use Legal & Compliance Templates
Lawyer‑drafted legal templates in downloadable Word format.
Frequently Asked Questions
What is a Fractional AML/CTF Compliance Officer?
A Fractional AML/CTF Compliance Officer is a senior AML lead who takes formal responsibility for your AML/CTF program & ML/TF/PF risk under your framework on a part-time, subscription basis instead of as a full-time employee.
How is this different from an AML/CTF consultant or one-off review?
Consultants & independent reviewers deliver projects; a fractional AML/CTF officer is your ongoing named owner for program design, oversight, monitoring & reporting, working with you month in, month out.
Can you be recorded as our AML/CTF Compliance Officer?
Yes – subject to scope & engagement terms, we can be recorded as your AML/CTF Compliance Officer & work directly with management & boards, while you retain overall responsibility as the reporting entity or licensee.
How does the subscription model work?
We agree a fixed monthly fee based on a defined AML/CTF scope – program & risk assessment oversight, KYC/CDD & monitoring oversight, AUSTRAC reporting, governance & training – reviewed periodically as your risk & operations change.
Do you replace our internal compliance team or work with them?
We can be the core AML/CTF function for smaller reporting entities, or oversee the framework & key decisions while your internal compliance, risk or operations teams handle day-to-day execution in larger organisations.
Do you only work with certain reporting entities?
Our primary focus is Australian reporting entities with meaningful AML/CTF obligations under the AML/CTF Act & Rules – including those providing financial, credit, payment, digital asset & other designated services. If you sit outside that core group but have real AML/CTF exposure, we can scope whether a fractional AML/CTF officer arrangement makes sense case by case.
What happens if AUSTRAC contacts us or we suspect a serious breach?
We help triage the issue, manage internal investigation & registers, structure SMRs or responses, & plan remediation, working alongside your leadership & legal team so engagement with AUSTRAC is coordinated & well-documented.
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