With over 15 years in Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) compliance, we offer an Australian AML audit solution to designated businesses and reporting entities, helping them comply with requirements of the AML/CTF Act 2006, AML/CTF Rules, and other relevant obligations, including Australian AML/CTF audit requirements outlined in Part 8.6 and Part 9.6 of the AML/CTF Rules.
AUSTRAC Guidance and Independent AML Review Requirements
If you search for Australian AML auditors online, everyone claims to be an expert, uses puffery language that AI chatbots write for them, and so on and so forth.
We are not just another AML/CTF audit provider firm that claims to have extensive knowledge of Australian AML compliance.
We are the ones who know what we are doing, having years of experience in all aspects of AML/CTF compliance, including:
- Creating and successfully enhancing anti-money laundering and counter-terrorist financing frameworks for different businesses tailored to their specific product, resources, risk appetites and sector-specific money laundering and terrorism financing risks
- Conducting AML/CTF risk assessments through a wide range of reporting entities
- Handling the first, second, and third lines of AML/CTF compliance and management.
- Conducting internal AML/CTF audits that go beyond statutory requirements
- Successfully assisting businesses in going through statutory AML/CTF reviews, including those conducted by the top four. We know a thing or two about good and bad AML auditors
- Acting as external AML/CFT auditors for designated service providers and reporting entities
- Helping AML/CTF reporting entities when things go wrong, including coordinating their risk and compliance teams, legal teams, external lawyers, and operations teams
- Helping businesses with Australian Transaction Reports and Analysis Centre (AUSTRAC) reviews
- Helping Australian reporting entities with their AML/CTF remediation
We have the necessary expertise to complete AML/CTF independent reviews and know what businesses want from their AML/CTF auditors.
Australian AML Audit Solutions’ Scope
We offer our AML audit solution to different types of AML/CTF reporting entities and designated service providers, including but not limited to:
- Investment bankers
- Investment firms
- Fund managers
- Brokers, including forex brokers
- Fintech companies
- Authorised Deposit takers
- Non-bank lenders
- Online casinos and gambling platforms
- Currency exchange providers
- E-money issuers
- Money remitters
- Payment gateway providers
- Derivatives Issuers and platforms
- Neo-banks
- P2P lending platforms
- Crowdfunding services and platforms
- Financial advisers
- Investment advisers
- Wealth managers
- Custodial or depository service providers
- Consumer credit providers
- Credit unions
- Corporate finance providers
- Finance companies
- Designated non-financial businesses and professions (DNFBPs), including trust and company formation providers (TCSPs)
Australian AML Audit’s Focus
Our Australian AML/CTF audits include, but are not limited to, independently reviewing and testing both AUSTRAC-recommended and compulsory focus areas:
- Whether you have properly addressed your money laundering and terrorism financing risks
- Whether Part A of your AML/CTF program is current and adequately assesses your policies and procedures for managing money laundering (ML) and terrorism financing (TF) risks
- Your ML/TF Risk Assessment's assumptions and conclusions
- Any changes to your ML/TF risk profile
- Any updates to your AML/CTF practices and policies
- The extent to which employees understand and comply with your AML/CTF program
- The effectiveness of your transaction monitoring systems in identifying suspicious matters
- Whether outsourced functions comply with Part A of your AML/CTF program.
- The implementation of Part A of your AML/CTF program by your branches and subsidiaries, including those overseas.
- Whether you comply with your obligations under the AML/CTF Act, including, but not limited to, the following areas:
- Initial customer due diligence requirements
- Beneficial ownership identification
- Screening
- Record-keeping
- Customer risk rating
- Ongoing customer due diligence
- Reporting timeliness and accuracy
- Transaction monitoring
- Governance and oversight
- Staff vetting and training
- Obligations covering the detection, escalation, and reporting of suspicious matters (SMRs), along with other statutory reporting obligations, including Threshold Transaction Reports (TTRs), International Funds Transfer Instructions (IFTIs), etc.
- Whether your AML/CTF Program is implemented as intended
- How effectively your business responded to previous recommendations by AUSTRAC or AML/CTF reviewers
- Post-implementation reviews assessing the effectiveness of changes made to Part A of your AML/CTF program.
- Root causes of identified deficiencies or violations, along with rectification plans
- The adequacy and effectiveness of your AML/CTF employee training program
- The seniority and authority of your AML/CTF compliance officer
Australian AML/CTF Audit Methodology
We can select and apply an appropriate methodology that works for your business or conduct an AML/CTF review using your audit methodology.
Australian AML Reviews Frequency
The frequency of AML/CTF audits in Australia depends on:
- Your business size
- Your products
- The complexity of the business
- Your ML/TF risk levels
In terms of AML/CTF obligations in Australia, this is between two and three years for higher ML/TF risk reporting entities. Also, AUSTRAC may require a business to conduct an AML audit.
AUSTRAC AML Compliance and Triggers for Independent AML Review
A requirement for an AML/CTF Audit in Australia may be triggered by a number of factors, including:
- Structural changes to your business
- Changes to the ML/TF risk of your business
- Changes in fund deposit or withdrawal methods
- Changes in outsourcing arrangements for ML/TF prevention functions
- Substantial changes to the AML/CTF Program
- Changes to the number or volume of transactions
- Substantial changes in markets of operations and customer types
- Introduction of new products
- Changes in delivery methods for your services
- AML/CTF remediation issues faced/completed by the business
Australian AML Audit Requirements and Independent Review Report
We issue detailed AML/CTF audit reports with findings and actionable recommendations. These reports outline:
- What was tested during the review
- The methodologies used in conducting the tests
- The sample sizes applied in the testing process
Our reports are designed to provide senior management and, where applicable, the governing board with clear insights into compliance performance.
Australian AML Audit Program & Audit Stages
Australian AML Audit process generally involves:
- Initial Meeting & Scope Definition:
- Defining the scope and objectives of the audit with the reporting entity
- Understanding the entity's business, risk profile, and existing AML/CTF program
- Documentation Review: Reviewing key AML/CTF documents
- Sampling & Testing: Performing sampling and testing of compliance with the AML/CTF Act and AML/CTF program. Examples include:
- Testing CDD procedures (customer identification & verification)
- Reviewing transaction monitoring alerts and SAR investigations
- Assessing the effectiveness of the risk assessment process
- Interviews & Inquiries:
- Interviewing key personnel (compliance officers, management, front-line staff)
- Inquiring about the implementation and effectiveness of AML/CTF controls
- Application of Audit Methodology:
- Applying appropriate audit methodologies, such as risk-based auditing, to assess the effectiveness of the AML/CTF program
- Report Preparation & Presentation:
- Preparing a comprehensive audit report
- Presenting findings, conclusions, and recommendations to management
AML/CTF Audit and Information Sampling
Australian AML audit requirements focus on evaluating how effectively a reporting entity complies with its obligations under the AML/CTF Act 2006 and its AML/CTF program. Independent audits typically involve reviewing samples of:
- Individual customers, including resident and non-resident clients, various types of corporate clients (e.g., limited liability companies, limited partnerships, and entities with complex beneficial ownership structures), as well as trusts and investment vehicles
- Customers presenting different ML/TF risks, including those categorised as medium- or high-risk
- Large, complex, or unusual transactions to determine how effectively the entity meets its transaction monitoring obligations
- Ad-hoc and periodic reports on customer transactions and activities, such as Suspicious Matter Reports (SMRs), threshold transaction reports (TTRs), and international funds transfer instruction (IFTI) reports, along with supporting documentation, to assess compliance with AUSTRAC reporting obligations
- AML/CTF training and staff vetting records
- Specialised client and transactional registers (e.g., high-risk clients, politically exposed persons (PEP) registers, etc.)
- Materials aimed at enhancing ML/TF risk awareness and operational compliance
- Records maintained for specific clients or/and transactions to verify compliance with record-keeping obligations under the Act
Australian Independent AML Review Solutions Tailored to Your Needs
When it comes to delivery, we:
- Focus on clear, concise, and objective assessments. No ego, no attitude, no puffery, and no jargon
- Have real knowledge of AML/CTF compliance and how each aspect works
- Use a client-centric approach. We understand the difference between your risk appetite, internal procedures, and AML/CTF requirements
- Cause minimal interruptions to your business (combining onsite and remote engagements)
- Provide comprehensive audit reporting
When it comes to flexibility, we:
- Offer realistic pricing options
- Tailor our approach to your specific needs and risk profile, offering limited assurance, reasonable assurance, and holistic options. We offer AML audit solutions to:
- Small businesses and startups
- Mid-sized businesses
- Business groups, including those with centralised compliance functions across subsidiaries, those operating across different compliance regimes, and offering a range of products
- High-risk corporates that come under regulatory scrutiny and pressure from important stakeholders, such as banking partners, insurance providers, and money remittance channels
Independent AML Review Preparation
We offer a comprehensive Internal AML Audit Review with the following features:
- Deeper Audit Focus, including:
- Evaluating the effectiveness of your AML/CTF compliance against your business goals, future objectives, wider risk appetite, and more
- Deep diving into the effectiveness of AML/CTF controls
- Covering specific review areas such as AML technology, process optimisation, and more.
- Flexible Scope: Designed with a flexible audit scope, which can be customised to your needs, as opposed to the Independent AML Review under the Australian AML/CTF law
- External Audit Preparation: Focused on internal improvement and identifying issues before external scrutiny, helping you prepare for an independent AML review, an enhanced review by a banking partner
- Regulatory review Preparation: Focused on preparing you for a review by AUSTRAC
- Non-binding findings: The audit report is confidential, giving you the opportunity to address any identified issues discreetly
- More information: Visit our Internal AML Review Solution page for more information
Related AML/CTF Solutions
In addition to our Australian AML audit option, we offer a comprehensive set of AML/CTF compliance solutions, helping you navigate the complexities of Australian AML requirements in a commercially oriented and goal-focused manner, providing effective support for all aspects of anti-money laundering compliance. Our focus areas include, but are not limited to:
- AML/CTF Advisory: We provide advisory solutions on a wide range of AML/CTF matters and issues. Visit our AML/CTF Advisory page for more.
- AML/CTF Compliance Management: We can fully manage your anti-money laundering and terrorist financing compliance. Visit our AML/CTF Compliance Management page for more.
- AML/CTF Risk Assessments: We conduct, review, and help businesses implement AML/CTF Risk Assessments that form the foundation of effective AML/CTF Programs. Visit our AML/CTF Risk Assessment page for more.
- AML/CFT Programs: We draft, review, and help businesses implement an AML/CTF Program based on the ML/TF risk assessment outcomes. Visit our AML/CTF Program page for more.
- AML/CTF Reg-tech Solutions: We help with AML/CTF technology integration tailored to your circumstances.
- AML/CTF Training: We offer specialised AML/CTF training solutions for different reporting entities. Visit our AML/CTF Training page for more.
- AML/CTF Procedures: We assist in developing and enhancing AML/CTF procedures tailored to your business needs, focusing on effective AML risk management across business processes.
- AML Manuals and Guidelines: We create and refine practical resources such as AML operating manuals and guidelines that provide step-by-step instructions to ensure efficient AML/CTF compliance based on your business size and complexity
- ML/TF Controls Mapping: We help map, assess, and enhance internal ML/TF controls to ensure compliance, address financial crime risks, and respond to findings from AML/CTF audits and supervisors.
- AML Red Flag Protocols: We develop guidelines for identifying and responding to red flags, enabling timely action against fraud, money laundering, and terrorist financing activities under various operational circumstances.
