Fractional AML/CTF Compliance Officer Services

Name: Click Legal Legal & Compliance Services
Brand: Click Legal
Rating: 5 (37 reviews)

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 Plans

Inclusions

Basic

Standard

Enhanced

Premium

Enterprise

$3,000/mo. +GST

$5,000/mo. +GST

$7,000/mo. +GST

$9,000/mo. +GST

$11,000/mo. +GST

Nominated AML/CTF Compliance Officer

Learn More

A Statutory Officer, Not Just an Adviser

We act as your nominated AML/CTF Compliance Officer. This is senior management-level role under the AML/CTF Act and Rules 2025. Fit and Proper person.

We are your point of contact with AUSTRAC on day-to-day matters.

Included

Nomination as your AML/CTF Compliance Officer, notified to AUSTRAC. Ongoing oversight of your AML/CTF obligations.

Frequency

Ongoing.

CAPS

An oversight role, day-to-day tasks, such as approving customer onboarding.

Out of scope

Acting as your registered reporting entity. You remain the reporting entity.

AML/CTF Program and Risk Assessment Maintained

Learn More

Keeping Your Program Current

We maintain your AML/CTF policy and risk assessment. Maintain policy aligned with the Act, the Rules 2025, and current AUSTRAC guidance.

Included

Review and maintenance of your existing policy and risk assessment.

Frequency

Ongoing. Reviewed at least once a year, or after a material change in your business.

CAPS

Maintenance of an existing policy and framework only.

Out of scope

Drafting a new policy and risk assessment from scratch. A full rewrite after a material change is quoted separately.

Hands-On Implementation Support

Learn More

Putting the Program into Practice

We help your team use the policy day to day. This can include setting up your compliance folders or answering set-up questions.

Included

Up to 2 sessions of 90 minutes per month. Virtual or onsite. Flexible rolling time.

Frequency

Monthly.

CAPS

3 hours total per month. Additional hours are billed at our standard hourly rates, available on request.

Out of scope

Ongoing operational tasks, such as data entry into registers.

AML/CTF Registers and Templates

Learn More

The Working Tools You Need

We set up the registers you need to evidence compliance. Examples include an SMR register, a TTR register, and a training register.

Included

Up to 3 template registers. Excel or Word based.

Frequency

One-off setup, in the first month.

CAPS

Standard templates only. Custom-built databases are extra.

Out of scope

Populating registers with your historical data.

Customer Due Diligence Oversight

Learn More

Testing KYC and CDD in Practice

We test that your due diligence settings work in practice. We sample real files across onboarding and ongoing monitoring.

Included

Review of up to 5 customer files per quarter.

Frequency

Quarterly.

CAPS

Sample-based testing only.

Out of scope

Performing due diligence checks yourself. Approving individual customer onboarding.

AML/CTF Reporting Support

Learn More

Reporting to Your Board

We help you prepare AML/CTF reports for your board or senior management.

Included

Review and input on 1 draft report per quarter.

Frequency

Quarterly.

CAPS

Up to 1 hour of review per quarter. Drafting from scratch is quoted at fixed rate.

Out of scope

Independent audit of the report’s accuracy.

Standard AML/CTF Staff Training

Learn More

General Awareness Training

A pre-prepared session on general AML/CTF topics. For example, an introduction to red flags.

Included

One 60-minute virtual session, for up to 20 staff, per quarter.

Frequency

Quarterly.

CAPS

Standard slides only. Customised content can be arranged at additional cost.

Out of scope

Role-specific training, such as separate content for frontline staff.

Annual Review of Your AML/CTF Program

Learn More

A Yearly Health Check

Once a year, we check your policy and risk assessment are still current and test CDD and KYC sampling. We send you a short summary finding report.

Included

Review the AML policy and risk assessment and bring up to date with business changes, legislation changes and new products.

Frequency

Annual.

CAPS

Review only. Major rewrites after major changes in business strategy or major legislative change are quoted separately.

Out of scope

Your periodic independent review. This is a separate engagement, to keep our review independent.

Regulatory Update Briefings

Learn More

Staying Ahead of AUSTRAC

A short call for enquires and proposal of new products or to flag anything new. This covers AUSTRAC guidance and AML/CTF Rules changes from the last quarter.

Included

One 30-minute call per quarter.

Frequency

Quarterly.

CAPS

General updates only. A major project arising from a change is scoped separately.

Out of scope

Implementing the changes for you.

Monthly Strategy Session

Learn More

Talking Strategy, Not Just Compliance

A monthly meeting on your business priorities. We talk through how to manage financial crime risk as you grow.

Included

One 60-minute call per month.

Frequency

Monthly.

CAPS

Strategy only. Work arising from the call uses your monthly hours.

Out of scope

Execution of strategy, such as running a project.

Transaction Monitoring and SMR/TTR/IFTI Oversight

Learn More

Overseeing How Suspicious Activity Is Handled

We oversee how suspicious activity is detected and reported. This covers your monitoring rules and alert handling.

Included

Review of alerts and case handling. Oversight of SMR, TTR and IFTI timeliness. Up to 4 hours per month.

Frequency

Monthly.

CAPS

4 hours per month. A high volume of alerts is scoped separately.

Out of scope

Being your first-line, real-time monitoring team.

Tailored AML/CTF Training for Staff

Learn More

Training Built Around Your Risks

Bespoke training for your business. We build a session around your actual products, customers and risks.

Included

One 90-minute tailored session per quarter.

Frequency

Quarterly.

CAPS

Up to 20 attendees. Extra sessions quoted separately.

Out of scope

Training for specialist roles, such as IT security.

Dedicated Support Line

Learn More

A Direct Line When You Need One

A direct line for quick questions. For example, whether a transaction is reportable.

Included

Up to 8 short advice touches per month. Calls or emails.

Frequency

Monthly.

CAPS

20 minutes per touch. Longer matters move to project work.

Out of scope

Drafting documents on the call.

Additional AML/CTF Documentation

Learn More

Beyond the Core Program

We draft other documents you need. Examples include board resolutions and process flow charts.

Included

Up to 3 additional standard documents per quarter.

Frequency

Quarterly, up to 12 per year.

CAPS

Standard templates or minor changes only.

Out of scope

Bespoke, high-value legal agreements.

Ongoing Strategic AML/CTF Consultation

Learn More

A Seat at the Table

We act as your executive AML/CTF Compliance Officer. We advise on financial crime risk at a strategic level.

Included

Two 60-minute strategic sessions per month.

Frequency

Monthly.

CAPS

Strategy and advice only. Execution, such as due diligence on a new product, is project work.

Out of scope

Representing you in negotiations.

AUSTRAC and Regulator Engagement

Learn More

Support If AUSTRAC Comes Calling

If AUSTRAC contacts you for an audit or a request, we help you prepare and attend meetings.

Included

Review of 2 draft responses per year. A 60-minute prep call per event.

Frequency

As needed, up to 2 events per year.

CAPS

2 events. Formal representation at a hearing is separate.

Out of scope

Defending against enforcement action or penalties.

Legacy Items and Remediation

Learn More

Always Out of Scope

Legacy items and remediation plans sit outside every plan. This includes historical issues and clearing a backlog.

Out of scope

Legacy AML/CTF issues, remediation plans, and remediation project work. Quoted separately, once we understand the scope.

Click Legal Portal

Learn More

Full access to our Click Legal Portal. This is our legal and compliance library of over 300 templates, checklists and guides, plus training material.

Compass by Click Legal

Learn More

Our monthly regulatory intelligence publication, for regulated financial services businesses.

Each edition covers key legal and regulatory developments, with practical next steps.

Minimum Term: 6 Months

Learn More

Every Click Legal fractional officer role carries a 6-month minimum term. This applies to General Counsel, AML/CTF Compliance Officer, Complaints Officer, and Privacy Officer. These are regulated, accountable functions, not short-term project work.

The term allows proper onboarding into your risk profile and history. It covers at least one full compliance cycle.

Terms: All plans can be tailored to your business. Prices are estimates for small to medium reporting entities. Final pricing depends on your size, complexity and risk profile. We reserve the right to give a custom quote.
A general compliance enquiry is a question answered by email or on a call, without a document review. Tailored documents are simple documents drafted for your business. Complex documents and tailored polices are quoted separately as a fixed fee.
Your AML/CTF registers are built from the information you give us. Legacy items and remediation plans are out of scope under every plan, and are quoted separately once we understand the scope. Independent reviews required under the AML/CTF Rules are also quoted and delivered separately, to keep our review independent of our Compliance Officer role.

Fractional General Counsel, Compliance Officer, Complaints Officer and Privacy Officer sit outside these plans. They are available separately. All fees are in Australian dollars per month and exclude GST.

Our plans are flexible

These plans are a starting point, not a straitjacket. No two reporting entities need the same mix of reviews and briefings each month, and we do not expect yours to.

If a month runs heavier than usual, for example an urgent escalation, we tell you before we start the work. We either carry it into the following month, or quote it as a fixed fee. Nothing is done quietly and charged to you later.

If your needs sit between two plans, we build the plan around what you actually need. At the end of each six-month term, we review how the plan has worked and adjust it with you.

Standard

$3,000/mo. +GST

Nominated AML/CTF Compliance Officer

All plans

A Statutory Officer, Not Just an Adviser

We act as your nominated AML/CTF Compliance Officer. This is senior management-level role under the AML/CTF Act and Rules 2025. Fit and Proper person.

We are your point of contact with AUSTRAC on day-to-day matters.

Included

Nomination as your AML/CTF Compliance Officer, notified to AUSTRAC. Ongoing oversight of your AML/CTF obligations.

Frequency

Ongoing.

CAPS

An oversight role, day-to-day tasks, such as approving customer onboarding.

Out of scope

Acting as your registered reporting entity. You remain the reporting entity.

AML/CTF Program and Risk Assessment Maintained

All plans

Keeping Your Program Current

We maintain your AML/CTF policy and risk assessment. Maintain policy aligned with the Act, the Rules 2025, and current AUSTRAC guidance.

Included

Review and maintenance of your existing policy and risk assessment.

Frequency

Ongoing. Reviewed at least once a year, or after a material change in your business.

CAPS

Maintenance of an existing policy and framework only.

Out of scope

Drafting a new policy and risk assessment from scratch. A full rewrite after a material change is quoted separately.

Click Legal Portal

All plans

Full access to our Click Legal Portal. This is our legal and compliance library of over 300 templates, checklists and guides, plus training material.

Compass by Click Legal

All plans

Our monthly regulatory intelligence publication, for regulated financial services businesses.

Each edition covers key legal and regulatory developments, with practical next steps.

Minimum Term: 6 Months

All plans

The term allows proper onboarding into your risk profile and history. It covers at least one full compliance cycle.

Hands-On Implementation Support

Included in Standard, Enhanced, Premium, Enterprise

Putting the Program into Practice

We help your team use the policy day to day. This can include setting up your compliance folders or answering set-up questions.

Included

Up to 2 sessions of 90 minutes per month. Virtual or onsite. Flexible rolling time.

Frequency

Monthly.

CAPS

3 hours total per month. Additional hours are billed at our standard hourly rates, available on request.

Out of scope

Ongoing operational tasks, such as data entry into registers.

AML/CTF Registers and Templates

Included in Standard, Enhanced, Premium, Enterprise

The Working Tools You Need

We set up the registers you need to evidence compliance. Examples include an SMR register, a TTR register, and a training register.

Included

Up to 3 template registers. Excel or Word based.

Frequency

One-off setup, in the first month.

CAPS

Standard templates only. Custom-built databases are extra.

Out of scope

Populating registers with your historical data.

Customer Due Diligence Oversight

Included in Standard, Enhanced, Premium, Enterprise

Testing KYC and CDD in Practice

We test that your due diligence settings work in practice. We sample real files across onboarding and ongoing monitoring.

Included

Review of up to 5 customer files per quarter.

Frequency

Quarterly.

CAPS

Sample-based testing only.

Out of scope

Performing due diligence checks yourself. Approving individual customer onboarding.

AML/CTF Reporting Support

Included in Standard, Enhanced, Premium, Enterprise

Reporting to Your Board

We help you prepare AML/CTF reports for your board or senior management.

Included

Review and input on 1 draft report per quarter.

Frequency

Quarterly.

CAPS

Up to 1 hour of review per quarter. Drafting from scratch is quoted at fixed rate.

Out of scope

Independent audit of the report’s accuracy.

Standard AML/CTF Staff Training

Included in Standard, Enhanced, Premium, Enterprise

General Awareness Training

A pre-prepared session on general AML/CTF topics. For example, an introduction to red flags.

Included

One 60-minute virtual session, for up to 20 staff, per quarter.

Frequency

Quarterly.

CAPS

Standard slides only. Customised content can be arranged at additional cost.

Out of scope

Role-specific training, such as separate content for frontline staff.

Annual Review of Your AML/CTF Program

Included in Enhanced, Premium, Enterprise

A Yearly Health Check

Once a year, we check your policy and risk assessment are still current and test CDD and KYC sampling. We send you a short summary finding report.

Included

Review the AML policy and risk assessment and bring up to date with business changes, legislation changes and new products.

Frequency

Annual.

CAPS

Review only. Major rewrites after major changes in business strategy or major legislative change are quoted separately.

Out of scope

Your periodic independent review. This is a separate engagement, to keep our review independent.

Regulatory Update Briefings

Included in Enhanced, Premium, Enterprise

Staying Ahead of AUSTRAC

A short call for enquires and proposal of new products or to flag anything new. This covers AUSTRAC guidance and AML/CTF Rules changes from the last quarter.

Included

One 30-minute call per quarter.

Frequency

Quarterly.

CAPS

General updates only. A major project arising from a change is scoped separately.

Out of scope

Implementing the changes for you.

Monthly Strategy Session

Included in Enhanced, Premium, Enterprise

Talking Strategy, Not Just Compliance

A monthly meeting on your business priorities. We talk through how to manage financial crime risk as you grow.

Included

One 60-minute call per month.

Frequency

Monthly.

CAPS

Strategy only. Work arising from the call uses your monthly hours.

Out of scope

Execution of strategy, such as running a project.

Transaction Monitoring and SMR/TTR/IFTI Oversight

Included in Premium, Enterprise

Overseeing How Suspicious Activity Is Handled

We oversee how suspicious activity is detected and reported. This covers your monitoring rules and alert handling.

Included

Review of alerts and case handling. Oversight of SMR, TTR and IFTI timeliness. Up to 4 hours per month.

Frequency

Monthly.

CAPS

4 hours per month. A high volume of alerts is scoped separately.

Out of scope

Being your first-line, real-time monitoring team.

Tailored AML/CTF Training for Staff

Included in Premium, Enterprise

Training Built Around Your Risks

Bespoke training for your business. We build a session around your actual products, customers and risks.

Included

One 90-minute tailored session per quarter.

Frequency

Quarterly.

CAPS

Up to 20 attendees. Extra sessions quoted separately.

Out of scope

Training for specialist roles, such as IT security.

Dedicated Support Line

Included in Premium, Enterprise

A Direct Line When You Need One

A direct line for quick questions. For example, whether a transaction is reportable.

Included

Up to 8 short advice touches per month. Calls or emails.

Frequency

Monthly.

CAPS

20 minutes per touch. Longer matters move to project work.

Out of scope

Drafting documents on the call.

Additional AML/CTF Documentation

Included in Enterprise

Beyond the Core Program

We draft other documents you need. Examples include board resolutions and process flow charts.

Included

Up to 3 additional standard documents per quarter.

Frequency

Quarterly, up to 12 per year.

CAPS

Standard templates or minor changes only.

Out of scope

Bespoke, high-value legal agreements.

Ongoing Strategic AML/CTF Consultation

Included in Enterprise

A Seat at the Table

We act as your executive AML/CTF Compliance Officer. We advise on financial crime risk at a strategic level.

Included

Two 60-minute strategic sessions per month.

Frequency

Monthly.

CAPS

Strategy and advice only. Execution, such as due diligence on a new product, is project work.

Out of scope

Representing you in negotiations.

AUSTRAC and Regulator Engagement

Included in Enterprise

Support If AUSTRAC Comes Calling

If AUSTRAC contacts you for an audit or a request, we help you prepare and attend meetings.

Included

Review of 2 draft responses per year. A 60-minute prep call per event.

Frequency

As needed, up to 2 events per year.

CAPS

2 events. Formal representation at a hearing is separate.

Out of scope

Defending against enforcement action or penalties.

Legacy Items and Remediation

Not included in any plan

Always Out of Scope

Legacy items and remediation plans sit outside every plan. This includes historical issues and clearing a backlog.

Out of scope

Legacy AML/CTF issues, remediation plans, and remediation project work. Quoted separately, once we understand the scope.

Standard

$5,000/mo. +GST

Nominated AML/CTF Compliance Officer

All plans

A Statutory Officer, Not Just an Adviser

We act as your nominated AML/CTF Compliance Officer. This is senior management-level role under the AML/CTF Act and Rules 2025. Fit and Proper person.

We are your point of contact with AUSTRAC on day-to-day matters.

Included

Nomination as your AML/CTF Compliance Officer, notified to AUSTRAC. Ongoing oversight of your AML/CTF obligations.

Frequency

Ongoing.

CAPS

An oversight role, day-to-day tasks, such as approving customer onboarding.

Out of scope

Acting as your registered reporting entity. You remain the reporting entity.

AML/CTF Program and Risk Assessment Maintained

All plans

Keeping Your Program Current

We maintain your AML/CTF policy and risk assessment. Maintain policy aligned with the Act, the Rules 2025, and current AUSTRAC guidance.

Included

Review and maintenance of your existing policy and risk assessment.

Frequency

Ongoing. Reviewed at least once a year, or after a material change in your business.

CAPS

Maintenance of an existing policy and framework only.

Out of scope

Drafting a new policy and risk assessment from scratch. A full rewrite after a material change is quoted separately.

Hands-On Implementation Support

Included in Standard, Enhanced, Premium, Enterprise

Putting the Program into Practice

We help your team use the policy day to day. This can include setting up your compliance folders or answering set-up questions.

Included

Up to 2 sessions of 90 minutes per month. Virtual or onsite. Flexible rolling time.

Frequency

Monthly.

CAPS

3 hours total per month. Additional hours are billed at our standard hourly rates, available on request.

Out of scope

Ongoing operational tasks, such as data entry into registers.

AML/CTF Registers and Templates

Included in Standard, Enhanced, Premium, Enterprise

The Working Tools You Need

We set up the registers you need to evidence compliance. Examples include an SMR register, a TTR register, and a training register.

Included

Up to 3 template registers. Excel or Word based.

Frequency

One-off setup, in the first month.

CAPS

Standard templates only. Custom-built databases are extra.

Out of scope

Populating registers with your historical data.

Customer Due Diligence Oversight

Included in Standard, Enhanced, Premium, Enterprise

Testing KYC and CDD in Practice

We test that your due diligence settings work in practice. We sample real files across onboarding and ongoing monitoring.

Included

Review of up to 5 customer files per quarter.

Frequency

Quarterly.

CAPS

Sample-based testing only.

Out of scope

Performing due diligence checks yourself. Approving individual customer onboarding.

AML/CTF Reporting Support

Included in Standard, Enhanced, Premium, Enterprise

Reporting to Your Board

We help you prepare AML/CTF reports for your board or senior management.

Included

Review and input on 1 draft report per quarter.

Frequency

Quarterly.

CAPS

Up to 1 hour of review per quarter. Drafting from scratch is quoted at fixed rate.

Out of scope

Independent audit of the report’s accuracy.

Standard AML/CTF Staff Training

Included in Standard, Enhanced, Premium, Enterprise

General Awareness Training

A pre-prepared session on general AML/CTF topics. For example, an introduction to red flags.

Included

One 60-minute virtual session, for up to 20 staff, per quarter.

Frequency

Quarterly.

CAPS

Standard slides only. Customised content can be arranged at additional cost.

Out of scope

Role-specific training, such as separate content for frontline staff.

Click Legal Portal

All plans

Full access to our Click Legal Portal. This is our legal and compliance library of over 300 templates, checklists and guides, plus training material.

Compass by Click Legal

All plans

Our monthly regulatory intelligence publication, for regulated financial services businesses.

Each edition covers key legal and regulatory developments, with practical next steps.

Minimum Term: 6 Months

All plans

The term allows proper onboarding into your risk profile and history. It covers at least one full compliance cycle.

Annual Review of Your AML/CTF Program

Included in Enhanced, Premium, Enterprise

A Yearly Health Check

Once a year, we check your policy and risk assessment are still current and test CDD and KYC sampling. We send you a short summary finding report.

Included

Review the AML policy and risk assessment and bring up to date with business changes, legislation changes and new products.

Frequency

Annual.

CAPS

Review only. Major rewrites after major changes in business strategy or major legislative change are quoted separately.

Out of scope

Your periodic independent review. This is a separate engagement, to keep our review independent.

Regulatory Update Briefings

Included in Enhanced, Premium, Enterprise

Staying Ahead of AUSTRAC

A short call for enquires and proposal of new products or to flag anything new. This covers AUSTRAC guidance and AML/CTF Rules changes from the last quarter.

Included

One 30-minute call per quarter.

Frequency

Quarterly.

CAPS

General updates only. A major project arising from a change is scoped separately.

Out of scope

Implementing the changes for you.

Monthly Strategy Session

Included in Enhanced, Premium, Enterprise

Talking Strategy, Not Just Compliance

A monthly meeting on your business priorities. We talk through how to manage financial crime risk as you grow.

Included

One 60-minute call per month.

Frequency

Monthly.

CAPS

Strategy only. Work arising from the call uses your monthly hours.

Out of scope

Execution of strategy, such as running a project.

Transaction Monitoring and SMR/TTR/IFTI Oversight

Included in Premium, Enterprise

Overseeing How Suspicious Activity Is Handled

We oversee how suspicious activity is detected and reported. This covers your monitoring rules and alert handling.

Included

Review of alerts and case handling. Oversight of SMR, TTR and IFTI timeliness. Up to 4 hours per month.

Frequency

Monthly.

CAPS

4 hours per month. A high volume of alerts is scoped separately.

Out of scope

Being your first-line, real-time monitoring team.

Tailored AML/CTF Training for Staff

Included in Premium, Enterprise

Training Built Around Your Risks

Bespoke training for your business. We build a session around your actual products, customers and risks.

Included

One 90-minute tailored session per quarter.

Frequency

Quarterly.

CAPS

Up to 20 attendees. Extra sessions quoted separately.

Out of scope

Training for specialist roles, such as IT security.

Dedicated Support Line

Included in Premium, Enterprise

A Direct Line When You Need One

A direct line for quick questions. For example, whether a transaction is reportable.

Included

Up to 8 short advice touches per month. Calls or emails.

Frequency

Monthly.

CAPS

20 minutes per touch. Longer matters move to project work.

Out of scope

Drafting documents on the call.

Additional AML/CTF Documentation

Included in Enterprise

Beyond the Core Program

We draft other documents you need. Examples include board resolutions and process flow charts.

Included

Up to 3 additional standard documents per quarter.

Frequency

Quarterly, up to 12 per year.

CAPS

Standard templates or minor changes only.

Out of scope

Bespoke, high-value legal agreements.

Ongoing Strategic AML/CTF Consultation

Included in Enterprise

A Seat at the Table

We act as your executive AML/CTF Compliance Officer. We advise on financial crime risk at a strategic level.

Included

Two 60-minute strategic sessions per month.

Frequency

Monthly.

CAPS

Strategy and advice only. Execution, such as due diligence on a new product, is project work.

Out of scope

Representing you in negotiations.

AUSTRAC and Regulator Engagement

Included in Enterprise

Support If AUSTRAC Comes Calling

If AUSTRAC contacts you for an audit or a request, we help you prepare and attend meetings.

Included

Review of 2 draft responses per year. A 60-minute prep call per event.

Frequency

As needed, up to 2 events per year.

CAPS

2 events. Formal representation at a hearing is separate.

Out of scope

Defending against enforcement action or penalties.

Legacy Items and Remediation

Not included in any plan

Always Out of Scope

Legacy items and remediation plans sit outside every plan. This includes historical issues and clearing a backlog.

Out of scope

Legacy AML/CTF issues, remediation plans, and remediation project work. Quoted separately, once we understand the scope.

Enhanced

$7,000/mo. +GST

Nominated AML/CTF Compliance Officer

All plans

A Statutory Officer, Not Just an Adviser

We act as your nominated AML/CTF Compliance Officer. This is senior management-level role under the AML/CTF Act and Rules 2025. Fit and Proper person.

We are your point of contact with AUSTRAC on day-to-day matters.

Included

Nomination as your AML/CTF Compliance Officer, notified to AUSTRAC. Ongoing oversight of your AML/CTF obligations.

Frequency

Ongoing.

CAPS

An oversight role, day-to-day tasks, such as approving customer onboarding.

Out of scope

Acting as your registered reporting entity. You remain the reporting entity.

AML/CTF Program and Risk Assessment Maintained

All plans

Keeping Your Program Current

We maintain your AML/CTF policy and risk assessment. Maintain policy aligned with the Act, the Rules 2025, and current AUSTRAC guidance.

Included

Review and maintenance of your existing policy and risk assessment.

Frequency

Ongoing. Reviewed at least once a year, or after a material change in your business.

CAPS

Maintenance of an existing policy and framework only.

Out of scope

Drafting a new policy and risk assessment from scratch. A full rewrite after a material change is quoted separately.

Hands-On Implementation Support

Included in Standard, Enhanced, Premium, Enterprise

Putting the Program into Practice

We help your team use the policy day to day. This can include setting up your compliance folders or answering set-up questions.

Included

Up to 2 sessions of 90 minutes per month. Virtual or onsite. Flexible rolling time.

Frequency

Monthly.

CAPS

3 hours total per month. Additional hours are billed at our standard hourly rates, available on request.

Out of scope

Ongoing operational tasks, such as data entry into registers.

AML/CTF Registers and Templates

Included in Standard, Enhanced, Premium, Enterprise

The Working Tools You Need

We set up the registers you need to evidence compliance. Examples include an SMR register, a TTR register, and a training register.

Included

Up to 3 template registers. Excel or Word based.

Frequency

One-off setup, in the first month.

CAPS

Standard templates only. Custom-built databases are extra.

Out of scope

Populating registers with your historical data.

Customer Due Diligence Oversight

Included in Standard, Enhanced, Premium, Enterprise

Testing KYC and CDD in Practice

We test that your due diligence settings work in practice. We sample real files across onboarding and ongoing monitoring.

Included

Review of up to 5 customer files per quarter.

Frequency

Quarterly.

CAPS

Sample-based testing only.

Out of scope

Performing due diligence checks yourself. Approving individual customer onboarding.

AML/CTF Reporting Support

Included in Standard, Enhanced, Premium, Enterprise

Reporting to Your Board

We help you prepare AML/CTF reports for your board or senior management.

Included

Review and input on 1 draft report per quarter.

Frequency

Quarterly.

CAPS

Up to 1 hour of review per quarter. Drafting from scratch is quoted at fixed rate.

Out of scope

Independent audit of the report’s accuracy.

Standard AML/CTF Staff Training

Included in Standard, Enhanced, Premium, Enterprise

General Awareness Training

A pre-prepared session on general AML/CTF topics. For example, an introduction to red flags.

Included

One 60-minute virtual session, for up to 20 staff, per quarter.

Frequency

Quarterly.

CAPS

Standard slides only. Customised content can be arranged at additional cost.

Out of scope

Role-specific training, such as separate content for frontline staff.

Annual Review of Your AML/CTF Program

Included in Enhanced, Premium, Enterprise

A Yearly Health Check

Once a year, we check your policy and risk assessment are still current and test CDD and KYC sampling. We send you a short summary finding report.

Included

Review the AML policy and risk assessment and bring up to date with business changes, legislation changes and new products.

Frequency

Annual.

CAPS

Review only. Major rewrites after major changes in business strategy or major legislative change are quoted separately.

Out of scope

Your periodic independent review. This is a separate engagement, to keep our review independent.

Regulatory Update Briefings

Included in Enhanced, Premium, Enterprise

Staying Ahead of AUSTRAC

A short call for enquires and proposal of new products or to flag anything new. This covers AUSTRAC guidance and AML/CTF Rules changes from the last quarter.

Included

One 30-minute call per quarter.

Frequency

Quarterly.

CAPS

General updates only. A major project arising from a change is scoped separately.

Out of scope

Implementing the changes for you.

Monthly Strategy Session

Included in Enhanced, Premium, Enterprise

Talking Strategy, Not Just Compliance

A monthly meeting on your business priorities. We talk through how to manage financial crime risk as you grow.

Included

One 60-minute call per month.

Frequency

Monthly.

CAPS

Strategy only. Work arising from the call uses your monthly hours.

Out of scope

Execution of strategy, such as running a project.

Click Legal Portal

All plans

Full access to our Click Legal Portal. This is our legal and compliance library of over 300 templates, checklists and guides, plus training material.

Compass by Click Legal

All plans

Our monthly regulatory intelligence publication, for regulated financial services businesses.

Each edition covers key legal and regulatory developments, with practical next steps.

Minimum Term: 6 Months

All plans

The term allows proper onboarding into your risk profile and history. It covers at least one full compliance cycle.

Transaction Monitoring and SMR/TTR/IFTI Oversight

Included in Premium, Enterprise

Overseeing How Suspicious Activity Is Handled

We oversee how suspicious activity is detected and reported. This covers your monitoring rules and alert handling.

Included

Review of alerts and case handling. Oversight of SMR, TTR and IFTI timeliness. Up to 4 hours per month.

Frequency

Monthly.

CAPS

4 hours per month. A high volume of alerts is scoped separately.

Out of scope

Being your first-line, real-time monitoring team.

Tailored AML/CTF Training for Staff

Included in Premium, Enterprise

Training Built Around Your Risks

Bespoke training for your business. We build a session around your actual products, customers and risks.

Included

One 90-minute tailored session per quarter.

Frequency

Quarterly.

CAPS

Up to 20 attendees. Extra sessions quoted separately.

Out of scope

Training for specialist roles, such as IT security.

Dedicated Support Line

Included in Premium, Enterprise

A Direct Line When You Need One

A direct line for quick questions. For example, whether a transaction is reportable.

Included

Up to 8 short advice touches per month. Calls or emails.

Frequency

Monthly.

CAPS

20 minutes per touch. Longer matters move to project work.

Out of scope

Drafting documents on the call.

Additional AML/CTF Documentation

Included in Enterprise

Beyond the Core Program

We draft other documents you need. Examples include board resolutions and process flow charts.

Included

Up to 3 additional standard documents per quarter.

Frequency

Quarterly, up to 12 per year.

CAPS

Standard templates or minor changes only.

Out of scope

Bespoke, high-value legal agreements.

Ongoing Strategic AML/CTF Consultation

Included in Enterprise

A Seat at the Table

We act as your executive AML/CTF Compliance Officer. We advise on financial crime risk at a strategic level.

Included

Two 60-minute strategic sessions per month.

Frequency

Monthly.

CAPS

Strategy and advice only. Execution, such as due diligence on a new product, is project work.

Out of scope

Representing you in negotiations.

AUSTRAC and Regulator Engagement

Included in Enterprise

Support If AUSTRAC Comes Calling

If AUSTRAC contacts you for an audit or a request, we help you prepare and attend meetings.

Included

Review of 2 draft responses per year. A 60-minute prep call per event.

Frequency

As needed, up to 2 events per year.

CAPS

2 events. Formal representation at a hearing is separate.

Out of scope

Defending against enforcement action or penalties.

Legacy Items and Remediation

Not included in any plan

Always Out of Scope

Legacy items and remediation plans sit outside every plan. This includes historical issues and clearing a backlog.

Out of scope

Legacy AML/CTF issues, remediation plans, and remediation project work. Quoted separately, once we understand the scope.

Premium

$9,000/mo. +GST

Nominated AML/CTF Compliance Officer

All plans

A Statutory Officer, Not Just an Adviser

We act as your nominated AML/CTF Compliance Officer. This is senior management-level role under the AML/CTF Act and Rules 2025. Fit and Proper person.

We are your point of contact with AUSTRAC on day-to-day matters.

Included

Nomination as your AML/CTF Compliance Officer, notified to AUSTRAC. Ongoing oversight of your AML/CTF obligations.

Frequency

Ongoing.

CAPS

An oversight role, day-to-day tasks, such as approving customer onboarding.

Out of scope

Acting as your registered reporting entity. You remain the reporting entity.

AML/CTF Program and Risk Assessment Maintained

All plans

Keeping Your Program Current

We maintain your AML/CTF policy and risk assessment. Maintain policy aligned with the Act, the Rules 2025, and current AUSTRAC guidance.

Included

Review and maintenance of your existing policy and risk assessment.

Frequency

Ongoing. Reviewed at least once a year, or after a material change in your business.

CAPS

Maintenance of an existing policy and framework only.

Out of scope

Drafting a new policy and risk assessment from scratch. A full rewrite after a material change is quoted separately.

Hands-On Implementation Support

Included in Standard, Enhanced, Premium, Enterprise

Putting the Program into Practice

We help your team use the policy day to day. This can include setting up your compliance folders or answering set-up questions.

Included

Up to 2 sessions of 90 minutes per month. Virtual or onsite. Flexible rolling time.

Frequency

Monthly.

CAPS

3 hours total per month. Additional hours are billed at our standard hourly rates, available on request.

Out of scope

Ongoing operational tasks, such as data entry into registers.

AML/CTF Registers and Templates

Included in Standard, Enhanced, Premium, Enterprise

The Working Tools You Need

We set up the registers you need to evidence compliance. Examples include an SMR register, a TTR register, and a training register.

Included

Up to 3 template registers. Excel or Word based.

Frequency

One-off setup, in the first month.

CAPS

Standard templates only. Custom-built databases are extra.

Out of scope

Populating registers with your historical data.

Customer Due Diligence Oversight

Included in Standard, Enhanced, Premium, Enterprise

Testing KYC and CDD in Practice

We test that your due diligence settings work in practice. We sample real files across onboarding and ongoing monitoring.

Included

Review of up to 5 customer files per quarter.

Frequency

Quarterly.

CAPS

Sample-based testing only.

Out of scope

Performing due diligence checks yourself. Approving individual customer onboarding.

AML/CTF Reporting Support

Included in Standard, Enhanced, Premium, Enterprise

Reporting to Your Board

We help you prepare AML/CTF reports for your board or senior management.

Included

Review and input on 1 draft report per quarter.

Frequency

Quarterly.

CAPS

Up to 1 hour of review per quarter. Drafting from scratch is quoted at fixed rate.

Out of scope

Independent audit of the report’s accuracy.

Standard AML/CTF Staff Training

Included in Standard, Enhanced, Premium, Enterprise

General Awareness Training

A pre-prepared session on general AML/CTF topics. For example, an introduction to red flags.

Included

One 60-minute virtual session, for up to 20 staff, per quarter.

Frequency

Quarterly.

CAPS

Standard slides only. Customised content can be arranged at additional cost.

Out of scope

Role-specific training, such as separate content for frontline staff.

Annual Review of Your AML/CTF Program

Included in Enhanced, Premium, Enterprise

A Yearly Health Check

Once a year, we check your policy and risk assessment are still current and test CDD and KYC sampling. We send you a short summary finding report.

Included

Review the AML policy and risk assessment and bring up to date with business changes, legislation changes and new products.

Frequency

Annual.

CAPS

Review only. Major rewrites after major changes in business strategy or major legislative change are quoted separately.

Out of scope

Your periodic independent review. This is a separate engagement, to keep our review independent.

Regulatory Update Briefings

Included in Enhanced, Premium, Enterprise

Staying Ahead of AUSTRAC

A short call for enquires and proposal of new products or to flag anything new. This covers AUSTRAC guidance and AML/CTF Rules changes from the last quarter.

Included

One 30-minute call per quarter.

Frequency

Quarterly.

CAPS

General updates only. A major project arising from a change is scoped separately.

Out of scope

Implementing the changes for you.

Monthly Strategy Session

Included in Enhanced, Premium, Enterprise

Talking Strategy, Not Just Compliance

A monthly meeting on your business priorities. We talk through how to manage financial crime risk as you grow.

Included

One 60-minute call per month.

Frequency

Monthly.

CAPS

Strategy only. Work arising from the call uses your monthly hours.

Out of scope

Execution of strategy, such as running a project.

Transaction Monitoring and SMR/TTR/IFTI Oversight

Included in Premium, Enterprise

Overseeing How Suspicious Activity Is Handled

We oversee how suspicious activity is detected and reported. This covers your monitoring rules and alert handling.

Included

Review of alerts and case handling. Oversight of SMR, TTR and IFTI timeliness. Up to 4 hours per month.

Frequency

Monthly.

CAPS

4 hours per month. A high volume of alerts is scoped separately.

Out of scope

Being your first-line, real-time monitoring team.

Tailored AML/CTF Training for Staff

Included in Premium, Enterprise

Training Built Around Your Risks

Bespoke training for your business. We build a session around your actual products, customers and risks.

Included

One 90-minute tailored session per quarter.

Frequency

Quarterly.

CAPS

Up to 20 attendees. Extra sessions quoted separately.

Out of scope

Training for specialist roles, such as IT security.

Dedicated Support Line

Included in Premium, Enterprise

A Direct Line When You Need One

A direct line for quick questions. For example, whether a transaction is reportable.

Included

Up to 8 short advice touches per month. Calls or emails.

Frequency

Monthly.

CAPS

20 minutes per touch. Longer matters move to project work.

Out of scope

Drafting documents on the call.

Click Legal Portal

All plans

Full access to our Click Legal Portal. This is our legal and compliance library of over 300 templates, checklists and guides, plus training material.

Compass by Click Legal

All plans

Our monthly regulatory intelligence publication, for regulated financial services businesses.

Each edition covers key legal and regulatory developments, with practical next steps.

Minimum Term: 6 Months

All plans

The term allows proper onboarding into your risk profile and history. It covers at least one full compliance cycle.

Additional AML/CTF Documentation

Included in Enterprise

Beyond the Core Program

We draft other documents you need. Examples include board resolutions and process flow charts.

Included

Up to 3 additional standard documents per quarter.

Frequency

Quarterly, up to 12 per year.

CAPS

Standard templates or minor changes only.

Out of scope

Bespoke, high-value legal agreements.

Ongoing Strategic AML/CTF Consultation

Included in Enterprise

A Seat at the Table

We act as your executive AML/CTF Compliance Officer. We advise on financial crime risk at a strategic level.

Included

Two 60-minute strategic sessions per month.

Frequency

Monthly.

CAPS

Strategy and advice only. Execution, such as due diligence on a new product, is project work.

Out of scope

Representing you in negotiations.

AUSTRAC and Regulator Engagement

Included in Enterprise

Support If AUSTRAC Comes Calling

If AUSTRAC contacts you for an audit or a request, we help you prepare and attend meetings.

Included

Review of 2 draft responses per year. A 60-minute prep call per event.

Frequency

As needed, up to 2 events per year.

CAPS

2 events. Formal representation at a hearing is separate.

Out of scope

Defending against enforcement action or penalties.

Legacy Items and Remediation

Not included in any plan

Always Out of Scope

Legacy items and remediation plans sit outside every plan. This includes historical issues and clearing a backlog.

Out of scope

Legacy AML/CTF issues, remediation plans, and remediation project work. Quoted separately, once we understand the scope.

Enterprise

$11,000/mo. +GST

Nominated AML/CTF Compliance Officer

All plans

A Statutory Officer, Not Just an Adviser

We act as your nominated AML/CTF Compliance Officer. This is senior management-level role under the AML/CTF Act and Rules 2025. Fit and Proper person.

We are your point of contact with AUSTRAC on day-to-day matters.

Included

Nomination as your AML/CTF Compliance Officer, notified to AUSTRAC. Ongoing oversight of your AML/CTF obligations.

Frequency

Ongoing.

CAPS

An oversight role, day-to-day tasks, such as approving customer onboarding.

Out of scope

Acting as your registered reporting entity. You remain the reporting entity.

AML/CTF Program and Risk Assessment Maintained

All plans

Keeping Your Program Current

We maintain your AML/CTF policy and risk assessment. Maintain policy aligned with the Act, the Rules 2025, and current AUSTRAC guidance.

Included

Review and maintenance of your existing policy and risk assessment.

Frequency

Ongoing. Reviewed at least once a year, or after a material change in your business.

CAPS

Maintenance of an existing policy and framework only.

Out of scope

Drafting a new policy and risk assessment from scratch. A full rewrite after a material change is quoted separately.

Hands-On Implementation Support

Included in Standard, Enhanced, Premium, Enterprise

Putting the Program into Practice

We help your team use the policy day to day. This can include setting up your compliance folders or answering set-up questions.

Included

Up to 2 sessions of 90 minutes per month. Virtual or onsite. Flexible rolling time.

Frequency

Monthly.

CAPS

3 hours total per month. Additional hours are billed at our standard hourly rates, available on request.

Out of scope

Ongoing operational tasks, such as data entry into registers.

AML/CTF Registers and Templates

Included in Standard, Enhanced, Premium, Enterprise

The Working Tools You Need

We set up the registers you need to evidence compliance. Examples include an SMR register, a TTR register, and a training register.

Included

Up to 3 template registers. Excel or Word based.

Frequency

One-off setup, in the first month.

CAPS

Standard templates only. Custom-built databases are extra.

Out of scope

Populating registers with your historical data.

Customer Due Diligence Oversight

Included in Standard, Enhanced, Premium, Enterprise

Testing KYC and CDD in Practice

We test that your due diligence settings work in practice. We sample real files across onboarding and ongoing monitoring.

Included

Review of up to 5 customer files per quarter.

Frequency

Quarterly.

CAPS

Sample-based testing only.

Out of scope

Performing due diligence checks yourself. Approving individual customer onboarding.

AML/CTF Reporting Support

Included in Standard, Enhanced, Premium, Enterprise

Reporting to Your Board

We help you prepare AML/CTF reports for your board or senior management.

Included

Review and input on 1 draft report per quarter.

Frequency

Quarterly.

CAPS

Up to 1 hour of review per quarter. Drafting from scratch is quoted at fixed rate.

Out of scope

Independent audit of the report’s accuracy.

Standard AML/CTF Staff Training

Included in Standard, Enhanced, Premium, Enterprise

General Awareness Training

A pre-prepared session on general AML/CTF topics. For example, an introduction to red flags.

Included

One 60-minute virtual session, for up to 20 staff, per quarter.

Frequency

Quarterly.

CAPS

Standard slides only. Customised content can be arranged at additional cost.

Out of scope

Role-specific training, such as separate content for frontline staff.

Annual Review of Your AML/CTF Program

Included in Enhanced, Premium, Enterprise

A Yearly Health Check

Once a year, we check your policy and risk assessment are still current and test CDD and KYC sampling. We send you a short summary finding report.

Included

Review the AML policy and risk assessment and bring up to date with business changes, legislation changes and new products.

Frequency

Annual.

CAPS

Review only. Major rewrites after major changes in business strategy or major legislative change are quoted separately.

Out of scope

Your periodic independent review. This is a separate engagement, to keep our review independent.

Regulatory Update Briefings

Included in Enhanced, Premium, Enterprise

Staying Ahead of AUSTRAC

A short call for enquires and proposal of new products or to flag anything new. This covers AUSTRAC guidance and AML/CTF Rules changes from the last quarter.

Included

One 30-minute call per quarter.

Frequency

Quarterly.

CAPS

General updates only. A major project arising from a change is scoped separately.

Out of scope

Implementing the changes for you.

Monthly Strategy Session

Included in Enhanced, Premium, Enterprise

Talking Strategy, Not Just Compliance

A monthly meeting on your business priorities. We talk through how to manage financial crime risk as you grow.

Included

One 60-minute call per month.

Frequency

Monthly.

CAPS

Strategy only. Work arising from the call uses your monthly hours.

Out of scope

Execution of strategy, such as running a project.

Transaction Monitoring and SMR/TTR/IFTI Oversight

Included in Premium, Enterprise

Overseeing How Suspicious Activity Is Handled

We oversee how suspicious activity is detected and reported. This covers your monitoring rules and alert handling.

Included

Review of alerts and case handling. Oversight of SMR, TTR and IFTI timeliness. Up to 4 hours per month.

Frequency

Monthly.

CAPS

4 hours per month. A high volume of alerts is scoped separately.

Out of scope

Being your first-line, real-time monitoring team.

Tailored AML/CTF Training for Staff

Included in Premium, Enterprise

Training Built Around Your Risks

Bespoke training for your business. We build a session around your actual products, customers and risks.

Included

One 90-minute tailored session per quarter.

Frequency

Quarterly.

CAPS

Up to 20 attendees. Extra sessions quoted separately.

Out of scope

Training for specialist roles, such as IT security.

Dedicated Support Line

Included in Premium, Enterprise

A Direct Line When You Need One

A direct line for quick questions. For example, whether a transaction is reportable.

Included

Up to 8 short advice touches per month. Calls or emails.

Frequency

Monthly.

CAPS

20 minutes per touch. Longer matters move to project work.

Out of scope

Drafting documents on the call.

Additional AML/CTF Documentation

Included in Enterprise

Beyond the Core Program

We draft other documents you need. Examples include board resolutions and process flow charts.

Included

Up to 3 additional standard documents per quarter.

Frequency

Quarterly, up to 12 per year.

CAPS

Standard templates or minor changes only.

Out of scope

Bespoke, high-value legal agreements.

Ongoing Strategic AML/CTF Consultation

Included in Enterprise

A Seat at the Table

We act as your executive AML/CTF Compliance Officer. We advise on financial crime risk at a strategic level.

Included

Two 60-minute strategic sessions per month.

Frequency

Monthly.

CAPS

Strategy and advice only. Execution, such as due diligence on a new product, is project work.

Out of scope

Representing you in negotiations.

AUSTRAC and Regulator Engagement

Included in Enterprise

Support If AUSTRAC Comes Calling

If AUSTRAC contacts you for an audit or a request, we help you prepare and attend meetings.

Included

Review of 2 draft responses per year. A 60-minute prep call per event.

Frequency

As needed, up to 2 events per year.

CAPS

2 events. Formal representation at a hearing is separate.

Out of scope

Defending against enforcement action or penalties.

Click Legal Portal

All plans

Full access to our Click Legal Portal. This is our legal and compliance library of over 300 templates, checklists and guides, plus training material.

Compass by Click Legal

All plans

Our monthly regulatory intelligence publication, for regulated financial services businesses.

Each edition covers key legal and regulatory developments, with practical next steps.

Minimum Term: 6 Months

All plans

The term allows proper onboarding into your risk profile and history. It covers at least one full compliance cycle.

Legacy Items and Remediation

Not included in any plan

Always Out of Scope

Legacy items and remediation plans sit outside every plan. This includes historical issues and clearing a backlog.

Out of scope

Legacy AML/CTF issues, remediation plans, and remediation project work. Quoted separately, once we understand the scope.

Fractional General Counsel, Compliance Officer, Complaints Officer and Privacy Officer sit outside these plans. They are available separately. All fees are in Australian dollars per month and exclude GST.

Our plans are flexible

These plans are a starting point, not a straitjacket. No two reporting entities need the same mix of reviews and briefings each month, and we do not expect yours to.

If your needs sit between two plans, we build the plan around what you actually need. At the end of each six-month term, we review how the plan has worked and adjust it with you.

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

“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.”

“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.”

“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.”

“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!”

“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.”

“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.”

“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.”

“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.”

“Handled the legal admin we avoided—contracts, policies, the lot—so we could focus on growing the business.”

“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.”

“As a freelancer, I needed a solid contract to protect my work and clarify terms with clients. Click Legal’s templates were a lifesaver—easy to use, legally sound, and written in plain English. Having a professionally drafted agreement gave me confidence and saved me from potential disputes. …

“As a technology executive who has built products, led strategy, and advised startups, I know how critical it is to have legal counsel who actually understands the pace and complexity of early-stage ventures. Hannah Deuk and the team at Click Legal bring exactly that: pragmatic, founder-focused legal advice without the unnecessary friction. …

“Hannah’s expertise has been invaluable for Paragon, providing us with exceptional regulatory legal support that has strengthened our compliance framework and safeguarded our operations. She has expertly prepared and reviewed critical documents such as Product Disclosure Statements (PDS), …

“Hannah has provided invaluable legal support to PKF Corporate Finance over a number of years, particularly in relation to our AFSL obligations and AML/CTF compliance. She brings deep regulatory expertise, a clear and practical approach, and is always responsive and professional. …

“Startups, meet your legal dream team Click Legal. They speak your language, understand scaling businesses, and deliver founder-friendly advice that fits your growth.”

“Hannah has been a huge help to me and my business. I offer products, services, memberships and events and she has looked at all my offerings and provided me with new documentation that was needed to ensure my business is protected. She is so easy to work with and …

“Thank you for your incredible patience and dedication throughout this entire process. The level of care & attention to every detail has been truly outstanding, and Click Legal has been deeply responsive – even late at night & over weekends.”

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.

In Financial Services & AML/CTF Law

0 + Years

AUSTRAC‑Regulated Businesses

0 + Sectors

Scope & Pricing Agreed Upfront

0 % Fixed-Fee

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

Hannah Deuk

Principal Lawyer & Founder, Sydney

Dominic Shaw

Lawyer, Sydney

Amira Hamit

Lawyer, Melbourne

Robert Williams

Lawyer, Melbourne

Jess Stolberg

Paralegal

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

Common AFSL Variation Triggers: A Detailed Guide for AFS Licensees

AFSL Variation, ASIC Notification or New Licence: Which One is Right for You?

Non-Cash Payment (NCP) Facilities: A Complete AFSL Guide for Australian Fintech & Payment Platforms

Responsible Manager Changes and AFSL Variations: When a Key Person Change Triggers Action

Operating Outside Your AFSL: Risks and How an AFSL Variation Can Help

How to Operate as a Corporate Authorised Representative Under an AFSL

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Ready-to-Use Legal & Compliance Templates

Lawyer‑drafted legal templates in downloadable Word format.

Property Management Policy Template (Australia)

For Australian responsible entities and fund managers

$399.00 +GST

Free Download for COMPASS Members

Consultancy Agreement (Pro-Supplier) Template (Australia)

For Australian consultants supplying business services

$39.00 +GST

Free Download for COMPASS Members

Contractor Agreement Template (Australia)

For Australian businesses engaging independent contractors

$39.00 +GST

Free Download for COMPASS Members

Business Advisor Agreement Template (Australia)

For Australian companies engaging business advisors

$39.00 +GST

Free Download for COMPASS Members

Workplace Grievance Policy Template (Australia)

$35.00 +GST

Free Download for COMPASS Members

Right to Disconnect Policy Template (Australia)

$59.00 +GST

Free Download for COMPASS Members

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.

CONTACT

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