Australian AML/CTF · Explainer

How to assess an AML service provider

Check who will do the work, what they will deliver and how you will accept it before you engage an AML adviser or outsourced service.

General information only, not legal, compliance, or other professional advice. Does not confirm compliance.

Start with: When does an AML program become a working process?

Define the engagement

An adviser may help design a procedure. An outsourced team may perform a check for you. A software licence may only provide the system your staff use. Describe each part of a bundled offer separately. AUSTRAC treats in-house technology and independent evaluation separately from the outsourcing arrangements covered by its guidance. Buying several services from one supplier does not make them the same service.

Compare the service before signingFollow the process from top to bottom. Define the work: Separate advice, case work and software. Inspect evidence: Ask the delivery team to explain a sample. Compare scope: Price the same work and exceptions. Agree acceptance: Record what you will check before sign-off.Define the work Inspect evidence Compare scope Agree acceptance
  1. Define the work

    Separate advice, case work and software.

  2. Inspect evidence

    Ask the delivery team to explain a sample.

  3. Compare scope

    Price the same work and exceptions.

  4. Agree acceptance

    Record what you will check before sign-off.

Compare the service before signing

Suggested review structure. Completing these steps does not confirm compliance.

Follow the process from top to bottom.

Suggested questions about the team

Use the following questions as a procurement aid, not a prescribed legal checklist. Who will work on your files after the sale? Which parts of your service have they handled before? Ask the proposed delivery team to explain one difficult case using fictional information. Record the answer and any limits. A senior person in the sales meeting may not be the person who provides the service.

Specify an output you can inspect

For a program engagement, ask for a sample contents list and a description of the information the provider needs from you. Set a review point before final delivery. For an ongoing service, describe a completed case file and the evidence you expect to receive. These are suggested acceptance methods. Avoid an acceptance test that only asks whether a document or dashboard exists.

Separate price from scope

Make a comparison sheet with separate rows for setup, case work, staff training, revisions and handover. Ask what happens when a file is incomplete or needs specialist attention. Record whether that work is included, charged separately or returned to your staff. Compare offers against the same fictional workload. A low monthly fee cannot tell you whether two proposals include the same work.

Check the agreement before signing

AUSTRAC describes written agreements with defined services, performance expectations and oversight arrangements. It also identifies restrictions on information sharing. Seek qualified advice on contract terms and the information your proposed arrangement can lawfully share. The questions on this page do not determine whether a particular agreement is legally sufficient.

Hypothetical example: two program quotes

A small practice receives two quotes. One includes a document and one meeting. The other includes interviews, a draft, a staff exercise and corrections. The practice asks both firms to price the same agreed scope. It records who will resolve unanswered questions before accepting delivery. This example explains a comparison method. It does not favour either pricing model or confirm that either proposal meets the practice’s obligations.

Sources and scope

Sources checked on 2026-09-06. This page is not continuously updated. Check the linked legislation and AUSTRAC guidance for current requirements.

This page does not cover: Vendor rankings and recommendations; Detailed legal advice on contracts, privacy or liability; Independent evaluation and statutory CDD reliance requirements.

Common AML/CTF terms