AML/CTF Program Design and Development
Who It's For:
Your AML/CTF Program is the bedrock of your money laundering, terrorist financing and non-proliferation financing risk mitigation strategy.
It articulates in detail what you are doing as a reporting entity to prevent these risks from occurring.
It must articulate in detail your Policies, Procedures, Systems & Controls that are in place to prevent your designated service(s) being utilised for nefarious reasons.
This service is essential for all new Tranche 2 businesses (Designated Non-Financial Businesses and Professions (DNFPBs)—including real estate agents, conveyancers, accountants, and lawyers) falling under the Australian AML/CTF regime in 2026.
From the 1st of July 2026, all reporting entities which provide designated services(s) as describe in the AML/CTF Act must develop and maintain and AML/CTF Program
Our Process:
We don't provide generic templates. We build a program that is defensible and tailored to your unique risk environment. Our process includes:
Gap Analysis & Risk Assessment Review: We start by thoroughly analysing your existing compliance frameworks (if any exist) and business model to understand your business and its specific ML/TF risks.
Policy Drafting & Design: We draft clear, concise, and compliant policies and procedures tailored to your sector, size, and risk appetite. This includes your overarching AML/CTF Program document, Customer Due Diligence (CDD) protocols, ongoing customer monitoring procedures and record keeping policies etc.
Integration & Implementation Planning: We help you integrate the new program into your daily operations, ensuring it's practical and actionable for your team.
Tangible Outcomes:
By the end of our engagement, you will receive:
A fully documented, AUSTRAC-ready AML/CTF Program that meets your new AML/CTF obligations
Clarity and Confidence: A clear understanding of your obligations and how to meet them.
A Foundation for Growth: A scalable compliance framework that supports your business as it expands.