AML Independent Review

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

Every business that has an AML/CTF Program is required to have it reviewed by an independent person regularly. These reviews may also be called an Independent Audit, 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 involve?

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.

An independent person can be someone internally if your business is large enough but they must not have been involved in the AML/CTF Program at all. You can also use an external person to conduct your AML/CTF review like AML Experts.

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

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 review 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 reviews 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.

Contact AML Experts

To get the peace of mind that only an independent review of your AML/CTF program can give, phone Paddy Oliver on 03 9636 3632 today.


William Hill Australia is captured by the AML/CTF Act as it provides online gambling products. William Hill Australia takes its legal obligations, and its reputation seriously. When it comes to having our AML/CTF Program subject to an independent review we want the auditor to be an AML/CTF Act subject matter expert and an experienced Independent Reviewer. Also, the auditor must have an excellent working knowledge of how an online gambling organisation such as William Hill Australia operates.

Paddy Oliver meets all our requirements as our independent program auditor. Over the years that Paddy has carried out our independent reviews we have found him to be extremely thorough in his auditing, but also practical in his recommendations. We also like the fixed price for the independent AML program review.

Do not hesitate to engage the AML Experts to carry out your independent review.

Porus Govekar

Compliance Manager
William Hill

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