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Independent review of AML/CTF program

Is your AML/CTF program ‘fit for purpose’?

The Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Act 2006 came into force on 12 December 2006. The Australian Government imposed a two year phased implementation period ending December 2008.


The most significant change is the movement from a prescriptive reporting regime to a risk management regime. This allows an organisation to implement the new requirements using a risk-based approach.

In this context, an organisation can determine and put in place risk-based systems and controls commensurate with the 'nature, size and complexity of its business and the type of money laundering and terrorism financing (ML/TF) risk that it might reasonably face'.

Since 12 December 2007, businesses delivering designated services are required to have an AML/CTF program in place. The purpose of an AML/CTF program is to help organisations avoid doing business with the wrong individuals or organisations.

A key requirement of all AML/CTF programs is to document how the organisation has identified, mitigated and managed its AML/CTF risk. The ever evolving world of AML/CTF legislative requirements, industry guidance and financial crime risks means that AML/CTF programs need to be ready to cope with change. Different stakeholders have different priorities and different points of view.

Failure to develop and implement a coherent and cogent AML/CTF program can lead to an organisation being vulnerable to both ML/TF risks and breaching its requirements under the AML/CTF legislation.

Criminal activity and breaches can damage reputation and be expensive in lost business and fines.

As a minimum, under the AML/CTF legislative requirements, an organisation must undertake an independent review of Part A of its AML/CTF program. The reviewer must be independent and suitably qualified.

Deloitte - Providing rigour and certainty to meet AML/CTF compliance

How can Deloitte help you?

  • Experienced AML/CTF practice, with dedicated partners with over 30 years’ collective AML/CTF experience
  • A robust and proportionate approach to independent reviews
  • An independent review tool DRigourTM based on our global experience and tailored to the Australian environment. DRigourTM uses a scorecard methodology to provide a visual assessment of an organisation’s AML/CTF program and is capable of drilling down to each component of the AML/CTF program
  • The opportunity to benchmark your AML/CTF program or constituent parts against peers in the market place. This benchmarking can be invaluable as a litmus test on progress and proportionality of a program.

An independent review across all components of your AML/CTF program can provide you with the rigour and certainty you need in complying with the AML/CTF legislation.

Contact us now to discuss further.


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