FAQs: Engaging AML/CTF Advisers by Reporting Entities

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We give below a set of FAQs as a guidance, when you are considering engaging us or any AML/CTF adviser/consultant to support you in your AML/CTF compliance efforts. 

 

Q1: What roles or services can we as an AML/CTF adviser provide to a reporting entity?

A: As an AML/CTF adviser (or consultant), we can help you with full range of services across AML/CTF and Sanctions, including:

• Understanding the money laundering (ML)/terrorist financing (TF)/proliferation financing (PF) risks relevant to your sector and your business,

• Advice on your AML/CTF obligations,

• Creating a tailored ML/TF/PF risk assessment,

• Developing a bespoke AML/CTF compliance program,

• Training/Awareness programmes for your directors and employees,

• Conducting independent reviews of your AML/CTF program (subject to no-conflict),

• Offer ongoing support like updates, technical advice, or maintenance of the compliance program,

• And more.

 

Q2: Are we registered with AUSTRAC / does AUSTRAC endorse or certify AML/CTF advisers?

A: No, AUSTRAC does not register or endorse AML/CTF advisers.

Consistent with the usual practice of regulators, AUSTRAC does not endorse or certify any adviser, firm, or solution (ie a tech solution). It does however acknowledges that reporting entities may engage advisers/consultants for their expertise in supporting their AML/CTF related work.

 

Q3: Who is responsible to meet legal obligations when engaging an AML/CTF adviser?

A: AUSTRAC guidance clarifies that a reporting entity remains responsible for ensuring its AML/CTF program meets the regulatory obligations. Engaging an external AML/CTF adviser does not reduce or take away a reporting entity’s accountability for compliance.  

 

Q4: What should I look for in a qualified AML/CTF adviser?

A: Key factors to consider include:

• Demonstrated knowledge via relevant qualifications or experience, with references or referees,

• Solid grasp of the AML/CTF regulatory framework and your legal obligations,

• Understanding (or ability to understand) your industry and its specific ML/TF risks.

These FAQs consider AUSTRAC guidance on appointing AML/CTF Advisers, which you can also refer to here.

25 November 2025

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Compliense Advisors is an AML/CTF and FinCrime compliance and risk management advisory firm.

Our experience includes implementing legislative changes; undertaking ML/TF risk assessment; setting up, implementing, uplifting AML/CTF program; and advising on AML/CTF and FinCrime compliance and risk matters.

The article above is for general awareness and informational purposes only. Please carefully evaluate your circumstances, and seek professional advice for your specific needs. You are responsible for your compliance obligations, and for any action taken or omitted. We are not a law firm, and do not provide legal advice.

Services to the Clients are provided under a signed Letter of Engagement (or a similar document), signed by both the parties.

Write to us on compliense@compliense.com.au. Visit our website for more such knowledge resources. You can also sign up for new articles and updates.