How to Choose the Right AML/CTF Adviser: A Step-by-Step Checklist Backed by AUSTRAC
In Australia, businesses that deal with money like remittance services, fintech companies and money transfer providers must follow strict laws to prevent money laundering and terrorism financing. These laws are part of the Anti Money Laundering and Counter Terrorism Financing Act 2006.
Choosing the wrong AML/CTF adviser, someone who doesn't understand the rules or your industry can lead to serious problems. That includes legal action, large fines and damage to your business reputation. This blog provides a step-by-step checklist based on AUSTRAC's official guidance to help you choose the right adviser for your business.
Step-by-Step Checklist for Choosing an AML/CTF Adviser
1. Check Relevant Qualifications and Industry Experience
| What to Check | Why It Matters |
|---|---|
| Adviser's AML/CTF certification and industry background | Ensures your adviser understands both your regulatory obligations and business model |
| References from similar clients | Helps validate their track record in managing AML compliance |
Avoid advisers who do not have real-world experience in your specific sector, such as digital remittances or fintech operations.
2. Ask if Their Risk Assessment is Customised
AUSTRAC warns against using template-based programs that don't reflect your specific risk environment. Your adviser should provide:
- A business-specific ML/TF risk assessment
- An AML/CTF program that considers your services, customer base, countries of operation, and delivery channels
| Good Practice | Poor Practice |
|---|---|
| Customised compliance plans | One-size-fits-all templates |
| Inclusion of your input in the process | No business-specific discussions |
Countries with higher ML/TF risks include parts of the Middle East, Africa, Eastern Europe, and some Pacific Islands, these must be factored in.
3. Training Must Match Your Business
AML/CTF training is a compliance requirement, not a formality. The adviser should deliver:
- Tailored training for your team
- Real examples of suspicious activity
- Clear responsibilities for reporting and handling financial compliance issues
Avoid general or superficial training sessions that tick boxes but don't build internal knowledge.
4. Independent Reviews Should Be Truly Independent
AUSTRAC's AML/CTF Rules (Part 8.6 and 9.6) require regular independent reviews of your AML program. This review must not be done by the person who designed your program.
Ensure your reviewer:
- Is not involved in creating your AML/CTF systems
- Tests your controls and interviews staff
- Delivers detailed findings and action points
Why This Matters: Pain Points Businesses Face
| Pain Point | Solution |
|---|---|
| Rising compliance costs | Hiring the right adviser prevents costly mistakes late |
| Confusion over what is compliance? | An expert adviser can clarify what legal compliance actually means for your business |
| Growing regulatory complexity | Advisers simplify navigation of changing AML/CTF regulations |
| Fear of failing audits | Ongoing reviews and customised training ensure audit readiness |
International Reach, Local Compliance: Consider Countries Involved
AML/CTF risk is higher in certain regions. Your adviser must understand how international factors affect your compliance:
| Country or Region | Risk Level | What to Monitor |
|---|---|---|
| Australia | Moderate | Local AML/CTF Act enforcement |
| Pacific Islands | High | Jurisdiction monitoring |
| South East Asia | Variable | Due diligence on remittance corridors |
| Middle East & Africa | High | Source of funds, transaction monitoring |
A good adviser includes all these factors in your AML/CTF risk assessment.
Quick Comparison: Good vs. Poor AML/CTF Advisers
| Good Adviser | Poor Adviser |
|---|---|
| Understands AUSTRAC compliance standards | Unfamiliar with AUSTRAC rules |
| Offers customised AML programs | Uses outdated templates |
| Includes you in the compliance process | Delivers reports without consultation |
| Provides engaging, practical training | Offers generic, brief sessions |
| Conducts real independent reviews | Performs checkbox audits |
Source: Based on AUSTRAC's "Checklist for Engagement of AML/CTF Adviser" (2022)
Common Mistakes to Avoid
- Choosing based on price alone (this increases compliance costs later)
- Failing to verify the adviser's legal compliance credentials
- Ignoring training quality
- Allowing conflicts of interest in reviews
Conclusion
Compliance is no longer optional, it's a must. But it doesn't have to be overwhelming. With the right AML/CTF adviser, you can confidently meet your compliance requirements, stay ahead of regulatory compliance expectations, and manage risks without inflating your compliance costs.
At RemitSo, we believe in simplifying AML/CTF compliance for remittance businesses. Our consultancy ensures all your financial compliance needs from risk assessment to training and independent reviews are managed effectively.
