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Rules Mate

Does Independent review of AML/CTF program apply to banks and ADIs?

A computed answer from the Rules Mate applicability engine, with the exact condition, the outcome for every structure and size, and the primary source.

Short answer: Yes

Yes. This obligation applies to banks and ADIs whatever their structure or size. The deciding fact: Authorised deposit-taking institution — AML/CTF reporting entity.

The obligation in brief

Independent review of AML/CTF program. Under the reformed AML/CTF Act, the former independent review of a Part A program has been replaced by an independent evaluation of the whole AML/CTF program (ML/TF risk assessment and AML/CTF policies). It must happen at least once every 3 years, at a frequency set in your AML/CTF policies.

Trigger: Having an AML/CTF program in place.

Why banks & adis get a different answer

Rules Mate runs its applicability engine across 9 business structures and 6 size bands for each of the 35 industries it maps. For 27 of those industries the answer for "Independent review of AML/CTF program" is no. Banks & ADIs is one of the 8 where the answer is different: yes.

The deciding fact for banks and ADIs: Authorised deposit-taking institution — AML/CTF reporting entity.

About the industry: Authorised deposit-taking institutions regulated by APRA under the Banking Act 1959.

Compare a professional services (general) business with 6–19 employees structured as a Pty Ltd company: the obligation does not apply (Requires an AML/CTF designated service).

Answer by business structure and size

Each cell is the engine's outcome for a business in banks & adis with that structure and size, assuming it sells to consumers and small businesses and holds customer contact details. "Check" means the obligation turns on a fact the industry does not settle.

"Independent review of AML/CTF program": outcome for banks and ADIs by structure and size
StructureNo employees1–5 employees6–19 employees20–99 employees100–499 employees500+ employees
Sole traderYesYesYesYesYesYes
PartnershipYesYesYesYesYesYes
TrustYesYesYesYesYesYes
Pty Ltd companyYesYesYesYesYesYes
Public companyYesYesYesYesYesYes
Not-for-profit (unregistered)YesYesYesYesYesYes
Registered charityYesYesYesYesYesYes
Super fundYesYesYesYesYesYes
Foreign companyYesYesYesYesYesYes

What the obligation requires

When due
At least once every 3 years, at the frequency set in your AML/CTF policies. Newly regulated entities: first evaluation due 30 June 2029 – 31 December 2030 depending on AUSTRAC account number.
Evidence to keep
Independent evaluation scope, evaluator independence record, evaluation report, governing body response, remediation tracker.
Maximum penalty
Civil penalty of up to $36.4M (body corporate) or $7.28M (individual), maximum per contravention, under the general AML/CTF Act civil penalty regime
Regulator
AUSTRAC
Jurisdiction
Commonwealth (national)

Other obligations where banks & adis differ from the norm

Other industries with a non-default answer

Questions

Does Independent review of AML/CTF program apply to banks and ADIs?
Yes. This obligation applies to banks and ADIs whatever their structure or size. The deciding fact: Authorised deposit-taking institution — AML/CTF reporting entity.
Is the answer the same for every industry?
No. For 27 of the 35 industries Rules Mate maps, the answer is no. Banks & ADIs is one of 8 industries with a different answer.

Related

Sources

Computed by the Rules Mate applicability engine from the published obligation corpus; facts last checked 3 October 2026. Rules Mate is not a law firm and this is general information, not legal advice. Confirm your position with the regulator source or a qualified adviser before acting.