Independent review of AML/CTF program
Reporting entities must arrange independent review of their Part A AML/CTF program at appropriate intervals.
Who must comply
All AUSTRAC reporting entities.
What triggers it
Having a Part A AML/CTF program in place.
When due
Appropriate intervals — risk-based; minimum recommended every 2 years.
Evidence required
Independent review scope, report, remediation tracker.
Max penalty
Same penalty regime as broader AML/CTF Act breaches; informs AUSTRAC enforcement posture
Summary
Section 84 + AML/CTF Rules Part 8.6 require reporting entities to ensure that the Part A program is subject to regular independent review. The review tests effectiveness, identifies improvements, and is documented for AUSTRAC. Typically annual for higher-risk entities, every 2-3 years for lower-risk.
Enforced by
Source legislation
Topics
Related obligations
- CWLTHEnrol with AUSTRAC as a reporting entityTranche 2 entities must enrol with AUSTRAC by 29 July 2026.
- CWLTHSuspicious matter, threshold, and IFTI reporting to AUSTRACLodge SMRs, TTRs ($10K+ cash), and IFTI reports via AUSTRAC Online.
- CWLTHCustomer due diligence (KYC) on every customerIdentify and verify every customer (and beneficial owner) before providing a designated service.
- CWLTHMaintain a written AML/CTF programEvery reporting entity needs a documented AML/CTF program — Part A risk + Part B systems.
- CWLTHDesignate an AML/CTF Compliance OfficerReporting entities must designate a senior employee as AML/CTF Compliance Officer.
- CWLTHDetect + enhance due diligence on Domestic + Foreign PEPsAML/CTF Rules require detection + EDD on Politically Exposed Persons (foreign + domestic + international organisation).
Frequently asked questions
- Who must comply with Independent review of AML/CTF program?
- All AUSTRAC reporting entities.
- What triggers Independent review of AML/CTF program?
- Having a Part A AML/CTF program in place.
- When is Independent review of AML/CTF program due?
- Appropriate intervals — risk-based; minimum recommended every 2 years.
- What is the maximum penalty for Independent review of AML/CTF program?
- Same penalty regime as broader AML/CTF Act breaches; informs AUSTRAC enforcement posture
- What evidence is required for Independent review of AML/CTF program?
- Independent review scope, report, remediation tracker.
Source: https://austrac.gov.au/business/core-guidance/aml-ctf-program/part-program/independent-review. Rules Mate is not a law firm. Always verify against the live regulator source before acting.