Engaging AML/CTF advisers

Reporting entities are the first line of defence in the fight against money laundering, terrorism financing (ML/TF) and other serious crime. A strong anti-money laundering and counter-terrorism financing (AML/CTF) program and culture is essential to ensuring Australia’s financial system is resilient against criminal and terrorist exploitation.

To assist your business understand and meet your AML/CTF obligations, you may choose to engage the services of an AML/CTF consultant or adviser. These advisers can provide a number of products and services including:

  • Building your understanding of the ML/TF risks facing your sector and your business
  • Providing advice on your AML/CTF obligations
  • Assisting you to develop a tailored money laundering and terrorism financing risk assessment for your business
  • Assisting you to develop a tailored AML/CTF program for your business
  • Training your staff on AML/CTF matters
  • Conducting independent reviews of your AML/CTF program

While it is not appropriate for AUSTRAC’s to endorse the services of any AML/CTF adviser or their products, we recognise that there are benefits and efficiencies to be gained from engaging the services of a third party consultant to assist you to understand and meet your AML/CTF obligations.

It is ultimately your responsibility to ensure that any third parties your business engages are suitably qualified and experienced to provide products and services that comply with your AML/CTF obligations.

To help you select an adviser who is suitably qualified and experienced to provide products and services for your business, we recommend that you consider a range of factors.

Before engaging an adviser, talk to them and consider the following factors about the person providing the services, and the services they provide.

The adviser
  • Do they demonstrate a sound knowledge of AML/CTF through relevant qualifications and/or experience providing AML/CTF advice, and can they provide details, referees or references?
  • Do they demonstrate a thorough understanding of the AML/CTF regulatory framework, and the legal obligations that your business must meet?
  • Do they demonstrate an understanding or capacity to understand your industry sector and business, and the money laundering and terrorism financing risks and operational challenges your business might reasonably face?

The services
  • Will they conduct a tailored ML/TF risk assessment to address the risks specific to your business?
  • Will they tailor the AML/CTF program to address the particular needs of your business, factoring in risks relevant to your customers, your services, and where and how you operate?
  • Do they clearly explain the services that they will provide to help you meet your AML/CTF obligations, including anything they cannot do?
  • Do they offer ongoing support services (e.g. risk updates, technical advice) to help you continuously maintain AML/CTF compliance?
  • Do they provide regular, practical, effective training to your staff, tailored to suit your business operating environment?
  • If you are engaging them for the purpose of a review, do they demonstrate independence from the development or operation of your AML/CTF program when conducting the review?

You can also download a sample checklist with more detailed factors to consider (PDF, 181KB)

Additional resources

This guidance sets out how we interpret the Act, along with associated Rules and regulations. Australian courts are ultimately responsible for interpreting these laws and determining if any provisions of these laws are contravened. 

The examples and scenarios in this guidance are meant to help explain our interpretation of these laws. They’re not exhaustive or meant to cover every possible scenario.

This guidance provides general information and isn't a substitute for legal advice. This guidance avoids legal language wherever possible and it might include generalisations about the application of the law. Some provisions of the law referred to have exceptions or important qualifications. In most cases your particular circumstances must be taken into account when determining how the law applies to you.

Last updated: 27 Jun 2023
Page ID: 148

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