AML Audit Australia
An AML audit is a commonly used term for an independent evaluation of an AML/CTF program. Under the current AML/CTF framework, reporting entities must provide for independent evaluations of their program at least every three years, with more frequent evaluations where appropriate. One AML provides independent AML evaluations and audit services for reporting entities across Australia, from targeted health checks through to full statutory independent evaluations.
We’re proud to assist small to enterprise-scale businesses across all industry sectors.
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What Is an AML Audit?
An AML audit is an independent assessment of your AML/CTF program, including your risk assessment, policies, procedures and relevant controls. It considers whether your program has been appropriately designed to meet your obligations and whether your business is identifying, assessing, managing and mitigating money laundering, terrorism financing and proliferation financing risks appropriately.
‘AML audit’ is a widely used commercial term. Under Australia’s AML/CTF requirements, the statutory term is ‘independent evaluation’. Throughout this page, we use both terms to reflect the terminology commonly used by businesses searching for this service and the terminology used under the current AML/CTF framework.
An AML audit or independent evaluation is different from a financial or accounting audit. It does not assess your financial statements or financial reporting. Instead, it focuses specifically on your AML/CTF program and your compliance with the applicable requirements.
Is an AML Audit a Legal Requirement in Australia?
Reporting entities must ensure their AML/CTF policies provide for independent evaluations of their AML/CTF program. These evaluations must occur at least once every three years, or more frequently where appropriate based on the nature, size, complexity and risk profile of the business.
The independent evaluation must be conducted by a person who is independent from the development, implementation and operation of the program, systems or controls being evaluated and who has sufficient knowledge and experience of AML/CTF matters.
A reporting entity is a business or individual that provides a designated service under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006. The specific obligations that apply depend on the designated services provided and any applicable transitional arrangements.
While ‘AML audit’ remains a commonly used search term, the relevant statutory requirement is for an independent evaluation.
Who Needs an AML Audit in Australia?
Businesses that provide designated services under the AML/CTF Act may be reporting entities and subject to the independent evaluation requirement. Designated services cover a range of financial and professional activities, including:
Financial services: Certain deposit-taking, lending, financial and related services
Remittance and money transfer: Businesses providing relevant remittance services
Digital currency exchange: Providers of designated digital currency exchange services
Tranche 2 services: Certain designated services provided by lawyers, accountants, conveyancers, real estate professionals and trust and company service providers
Being part of a particular industry does not automatically make a business a reporting entity. The obligation depends on whether the business provides a designated service covered by the AML/CTF Act.If you are unsure whether your business is a reporting entity or whether an independent evaluation applies to you, [book a consultation] and we can help clarify your position.
What Does an AML Audit Cover?
The scope of an AML audit or independent evaluation depends on the engagement, your designated services, business size and complexity, and your risk profile. A statutory independent evaluation considers your risk assessment, AML/CTF program and how your business is managing its relevant financial crime risks.
AML/CTF Program Review
We assess your AML/CTF program and related policies and procedures against the applicable requirements of the AML/CTF Act and Rules. This includes considering whether the program is appropriate for your business and risk profile.
Risk Assessment
We review how your business identifies and assesses its money laundering, terrorism financing and proliferation financing risks and whether the controls in your program appropriately address those risks.
Operational Testing
Where included in the engagement scope, we examine relevant records, files and processes to assess how your AML/CTF controls are being applied in practice. The nature and extent of testing depends on the agreed scope and your business.
Findings and Recommendations
A statutory independent evaluation results in a written report setting out the evaluator's findings and recommendations. This gives your business a clear record of areas requiring attention and helps prioritise remediation.
One AML will agree an appropriate scope with you before the engagement begins, based on your business, obligations and risk profile.
The Difference Between an AML Audit and a Health Check
The terms can sometimes be used interchangeably in the market, but One AML uses them to describe different service levels.
A One AML Health Check is an advisory service. It provides an independent, desk-based review of your AML/CTF program documentation, with practical recommendations to help identify and address gaps. It does not satisfy the statutory independent evaluation requirement.
A One AML Review or Premium Review is a statutory independent evaluation. The scope includes operational testing appropriate to the engagement and a formal findings and recommendations report.
If you need to meet your statutory independent evaluation obligation, we can help determine the appropriate engagement for your business.
Our AML Audit Packages
Health Check From $2,500
A desk-based review of your AML/CTF program documentation with a written recommendations report. Suitable for businesses that want independent feedback on their program before a formal statutory independent evaluation.
Includes:Desk-based documentation review
Written recommendations report
Health Check Plus POA
Desk-based documsentation review plus limited operational testing of a small sample of processes, with a written recommendations report.
Includes:
Desk-based review of program documentation
Limited operational testing (small sample)
Written recommendations report
Prioritised findings
Review POA
Statutory independent evaluation of your AML/CTF program. Includes operational testing of processes in Part A of your program using a large sample, with a formal findings and recommendations report. Satisfies your independent evaluation obligation under the AML/CTF Act.
Includes:
Desk-based documentation review
Operational testing of Part A (large sample)
Formal findings and recommendations report
Premium Review POA
Full statutory independent evaluation of your AML/CTF program, with scope covering Parts A and B as appropriate to your business. Includes a formal findings and recommendations report and a post-audit remediation review.
Includes:
Desk-based documentation review
Operational testing of Parts A and B (large, tailored sample)
Formal findings and recommendations report
Post-audit remediation review
Our AML Audit Process
- Step 1: Scoping and planning: We discuss your business, designated services, AML/CTF program and risk profile to determine an appropriate scope. We also confirm the timing, documents required and approach to operational testing.
- Step 2: Document collection: We collect your AML/CTF program, risk assessment, policies, procedures and relevant supporting records based on the agreed scope.
- Step 3: Documentation review: We assess your documentation against the applicable AML/CTF requirements and consider whether your program is appropriate for your business and risks.
- Step 4: Operational testing: Where included in your engagement, we examine relevant files, records and processes to assess how your controls are being applied in practice.
- Step 5: Findings report: We provide a written report explaining our findings and recommendations, with clear priorities to help you determine what needs attention.
- Step 6: Remediation review: Premium Review clients receive a follow-up review after remediation to assess whether identified issues have been addressed.
What Happens If the Audit Identifies Compliance Issues?
Identifying gaps is an important part of an independent evaluation. The purpose is to give your business an independent assessment of its AML/CTF program and identify areas that need attention.
Our findings report provides recommendations and helps you prioritise remediation. If further support is required, our Consulting and Advisory team can assist with addressing identified gaps.
Premium Review clients can also access a post-evaluation remediation review to assess the changes made following the evaluation.
AML Audit and Tranche 2 Reporting Entities
Tranche 2 AML/CTF obligations commenced on 1 July 2026, bringing additional designated services within the AML/CTF framework.
Newly regulated businesses are subject to transitional arrangements for their first independent evaluation. The applicable deadline is staggered according to the entity's AUSTRAC account number.
If you became a reporting entity under Tranche 2 and are unsure when your first independent evaluation is due, One AML can help you understand the applicable requirements and plan your evaluation.
Starting early also gives your business time to address any findings before the evaluation deadline.
Why Choose One AML for Your AML Audit?
One AML has conducted independent evaluations for more than 1,000 reporting entities across Australia and New Zealand. Our team combines AML/CTF regulatory knowledge with practical experience across different business models and sectors.
- Independent evaluations conducted by suitably experienced AML/CTF specialists
- Practical assessment of your AML/CTF program and controls
- Service options ranging from health checks to comprehensive evaluations
- Clear findings and practical recommendations
- Post-evaluation remediation support available
- Ongoing Consulting and Advisory support
- AMLCO Support Services available
- 70+ verified Google reviews
We’re qualified to consult for all Phase 1 and 2 reporting entities across Australia.
Accounting
Financial Services
Law
Other Captured Sectors
Real Estate
Virtual Assets / Crypto
Book Your AML Audit Today
Whether your independent evaluation is approaching or you want an independent view of your AML/CTF program, One AML can help you understand your compliance position and address issues with confidence.
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