Holley Nethercote advises on risk-based AML/CTF procedures, including customer onboarding, reporting obligations (such as SMRs and IFTIs), and the development of tailored ML/TF Risk Registers and AML/CTF Programs. We review your governance and oversight arrangements and recommend practical enhancements to ensure compliance with AML/CTF obligations.
We also advise on broader financial crime matters, including Proceeds of Crime legislation, and assist with AUSTRAC registration, reporting, regulatory engagement, investigations, remediation plans, and independent AML/CTF reviews. Our team regularly acts as a liaison with AUSTRAC and supports clients in responding to regulatory action or potential breaches.
Updated AML/CTF Programs – Now Live
Our AML/CTF Program suite has been updated to reflect changes to the AML/CTF Act and Rules, the expanded scope of designated services and current regulatory guidance.
We offer flexible options depending on your business size, risk profile and internal capability.
DIY AML/CTF Program Templates
Our template programs are designed for businesses that want a structured, regulator-ready starting point.
They include policy templates, ML/TF Risk Assessment templates, registers, AUSTRAC guidance and practical tools to support implementation.
Custom “Do-It-For-Me” AML/CTF Programs
For businesses requiring tailored support, we develop a custom AML/CTF Program through interviews and questionnaires, aligned to your designated services and ML/TF risk profile.
This option is suited to higher-risk businesses or those seeking end-to-end compliance support.
| AML/CTF Program Options |
AML/CTF Independent Reviews
What is an AML/CTF independent review?
AUSTRAC explains that an independent review is an impartial assessment of Part A of your AML/CTF Program, and considers the effectiveness of Part A of the Program, whether Part A complies with the AML/CTF laws, whether your business has effectively implemented the policies and procedures set out in Part A, and whether your business has complied with the obligations set out on Part A.
Who can conduct an independent review?
The person that you appoint to conduct the independent review can be either an internal employee, or an external consultant, however, they must be independent.
How often should an independent review be conducted?
In our experience, most reporting entities determine that a 2-3 year period between reviews is appropriate.
For more information on AML/CTF independent reviews, and what’s involved, read our article “Why your AML/CTF Program needs to be independently reviewed regularly“.
AML/CTF Training
Training is a core component of AML/CTF compliance. We offer updated AML/CTF training to support both program rollout and ongoing obligations, including:
• Foundation AML/CTF training
• Topic-specific training (including SMRs)
• Staff-wide training solutions and bundles
Role-specific and additional topic-specific training modules are coming soon.
| View AML/CTF Training Options |
