AML Experts | Independent AML/CTF Reviews for Australian Businesses

When was the last time your AML/CTF Program was independently reviewed or evaluated?

Every business that has an AML/CTF Program is required to have it reviewed/evaluated by an independent person regularly. These reviews may also be called an Independent Evaluation, an Independent Audit, an AML/CTF Program Review or an AML/CTF Program Audit. The objective of the review should not just be to make sure you’re complying with the law, it should also help your business improve its processes so you’re at the forefront of AML/CTF process and policy.

What does an AML/CTF Review under Rule 8.6 involve? (Until March 2026)

An independent AML/CTF review looks at the effectiveness of your business processes. It includes testing:

How effective your AML-CTF program is;
Whether your AML-CTF Program is in line with the AML/CTF laws and regulations;
Whether your AML-CTF Program has been implemented effectively; and
Whether you have followed your AML-CTF program.

What does an AML/CTF Evaluation involve? (From April 2026)

An independent AML/CTF evaluation looks at the effectiveness of your business processes. It must include the following:

(a) evaluation of the steps taken by the reporting entity when undertaking or reviewing the reporting entity's ML/TF risk assessment, against the requirements of the Act, the regulations and the AML/CTF Rules;
(b) evaluation of the design of the reporting entity's AML/CTF policies, against the requirements of the Act, the regulations and the AML/CTF Rules;
(c) testing and evaluation of the compliance of the reporting entity with the reporting entity's AML/CTF policies:
(d) production of a written report (an independent evaluation report) containing findings on the matters mentioned in paragraphs (a) to (c);
(e) delivery of the independent evaluation report to the governing body of the reporting entity and to any senior manager responsible for approvals under section 26P of the Act

The AML/CTF policies of the reporting entity must deal with how the reporting entity will respond to an independent evaluation report.

An independent evaluation must be conducted at least once every 3 years, if not sooner.

For the purposes of subparagraph 26F(3)(c)(ii) of the Act, the AML/CTF policies of a reporting entity must deal with reviewing and updating the AML/CTF policies in response to an independent evaluation report that contains adverse findings in relation to the AML/CTF policies.

Should you use an external person to conduct your AML/CTF review / evaluation?

While some large businesses may let their internal audit department conduct their independent review, most businesses prefer to bring in someone external to either complete the review or provide support and expertise.

There are several reasons why businesses choose to use an external person to conduct their independent review. These include:

They do not have the resources or capacity to devote to an AML/CTF Program Review.
They want to make sure their business can benefit from industry best practices.
An external reviewer gives AUSTRAC and other stakeholders additional assurance and protection.
It’s often easier for bad news to be delivered by someone external to the business

If you choose to use an external person to do your independent AML/CTF program review, don’t choose someone who just ticks boxes. AML Experts won't just review your business, we'll help you improve it.

AML Experts work with you to improve your business

An independent evaluation shouldn't just be about ticking boxes - it should help you identify ways to improve the effectiveness and efficiency of your AML/CTF Program. When conducting independent AML/CTF Program evaluations we have helped clients:

Reduce their operating costs
Simplify their AML/CTF Program
Tighten their controls without increasing administration
Identify where their AML/CTF Program is strongest and weakest
Identify how their policies and procedures need to change
Implement new processes
Give the Board and senior management comfort around their AML governance responsibilities

Our team includes experienced AML/CTF Program Independent Reviewers who have carried out many independent reviews since the inception of the AML Act, and written and implemented AML/CTF Programs. Our independent reviews also include:

Fixed price with several options to suit your specific needs and budget.
Practical advice from subject matter experts delivered in plain English.
A set methodology so you know exactly what to expect and why it’s being done.
Minimal disruption to your business by using off-site document reviews where possible along with on-site interviews and control testing.
An appraisal of your AML/CTF Program compliance framework.
Sign off from our Auditors to give your Board the confidence to get back to business.
A genuine concern for your business. We’re not focused on winning remediation work, we want your business to get the most from our expertise.

An AML Experts Independent Review is more than just due diligence. It’s 100% peace of mind.