Publications

AML/CTF Independent Reviews

Feb 19, 2025 | ClubHub, Publications

Members should be aware that as part of AUSTRAC’s upcoming Annual Compliance Report (ACR), due by 31st March 2025, you are required to submit information regarding your most recent independent review of PART A of AML/CTF program.

What is an independent review of the AML/CTF Part A Program?
An independent review is an impartial assessment of a reporting entity’s current Anti-Money Laundering/ Counter-Terrorism Financing (AML/CTF) Part A Program to:

• Assess their effectiveness of the Part A Program having regard to ML/TF risk;

• Assess whether their Part A Program complies with the AML/CTF Rules;

• Assess whether their Part A Program has been effectively implemented; and

• Assess whether they complied with their Part A Program

Why is it required to perform an independent review of Reporting Entities AML/CTF Part A Program?
To meet the requirements of the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Rules Instrument 2007 (No. 1) under either of the below:

Part 8.6 for a reporting entity that has adopted a Standard AML/CTF program or
Part 9.6 for reporting entities that have enrolled as a Designated Business Group (DBG) and adopted a joint AML/CTF Program

• Apart from regulatory requirement, independent review reports of AML/CTF Part A Program are required to be presented by reporting entities to their Board and Senior Management to demonstrate their current level of compliance in meeting the requirements of their Part A program.

Does independent review need to examine all areas of Part A Program?

Independent reviews can examine some or all areas of the Part A Program. During 2024, AUSTRAC published their regulatory priorities. Members may consider focusing their reviews on these key risk areas in addition to those that impact their specific business operations.

Who can conduct an independent review?
You can choose an independent reviewer (including external provider) who has not been involved in:

• performing any of the functions or measures being reviewed

• designing, implementing or maintaining Part A of your AML/CTF program

• developing your money laundering/terrorism financing risk assessment or related internal systems and controls.

Need further assistance?
The above explanations are designed to give you an overview of the independent review requirements that binds your club.

AML SureCheck ™ is CCV’s specialist AML/CTF independent review service provider offering over 20 years of experience across highly regulated sectors. It is led by Giridhar Kannan (Giri), a Professional Member of the institute of Internal Auditors – Australia and also an Advanced CAMS Audit certified professional. He is also a sessional faculty at University of Sydney, Business School for the subject ‘International Financial Crime’.

AML SureCheck ™ offers discounted, fixed rates exclusively for CCV members. Their reviews are tailored to meet the specific needs of each club, ensuring compliance with AUSTRAC regulatory priorities and also help meet ACR submission deadlines.

Contact AML SureCheck™
For more information or to book an independent review, contact Giri Monday to Friday during business hours:
Phone: 0423 025 101
Email: [email protected]