An independent review is a structured assessment of your AML/CTF program by someone who is not involved in its day-to-day operation. The Rules don't prescribe a frequency, but the practical industry baseline is annually for the first two years of a new program, then every two years for stable, low-risk SMEs.
Who can do it
- An external compliance consultant with documented AML experience — most common for SMEs.
- An internal staff member who is independent of the AML function — viable for larger firms.
- A managed-service provider doing the review for a client they don't otherwise service — increasingly common.
What the review covers
- Adequacy of the documented program against the current Rules.
- Sample testing of CDD, screening and monitoring outcomes.
- SMR/TTR completeness and accuracy.
- Training currency and attestation evidence.
- Recommendations with priority ratings and a remediation timeline.
What it costs
Expect A$2,500–A$6,000 for a sole-practitioner review, A$6,000–A$15,000 for a 5–20 person firm, and A$15,000+ for multi-office firms. Bundled reviews from your AML platform provider sit at the low end; specialist consultancies sit at the high end.