Australian AML/CTF · Explainer

How should you oversee an external compliance provider?

Give external providers clear tasks, evidence requirements and an escalation route while retaining business oversight.

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

Start with: Does AML regulation follow your service or your profession?

Define the function purchased

An external provider can supply specialist capacity, but the business still needs a clear operating arrangement. AUSTRAC explains that an external compliance officer needs appropriate authority, resources and expertise. The officer coordinates work rather than personally completing every task. Start by naming the function you are buying and the decisions the provider can make. Separate advice, operational delivery and oversight. A service described only as AML support can leave both parties with different expectations about who will identify problems and ensure action follows.

Specify the evidence and handover

A useful statement of work identifies the tasks, information required, expected output and person who accepts that output. Include how the provider raises incomplete information and who responds within the business. For recurring work, agree how changes to services and procedures reach the provider. Ask for evidence that supports the task performed, rather than a generic monthly assurance statement. This is a suggested contract-management method, not a prescribed legal form or a statement that a supplier can assume the business’s responsibilities.

Follow one outsourced taskFollow the process from top to bottom. Business instruction: Describe the task and supply the needed information. Provider output: Return the work and identify gaps or unresolved questions. Business acceptance: Check the output and allocate the remaining action.Business instruction Provider output Business acceptance
  1. Business instruction

    Describe the task and supply the needed information.

  2. Provider output

    Return the work and identify gaps or unresolved questions.

  3. Business acceptance

    Check the output and allocate the remaining action.

Follow one outsourced task

Read this visual with the source conditions and explanation in this section.

Follow the process from top to bottom.

Example: reviewing an issue register

Imagine an adviser is engaged to review the business’s issue register. The adviser sends recommendations, but no staff member owns the response. A practical improvement is to assign each accepted action to a business owner and record what will demonstrate completion. Keep unresolved recommendations visible for the appropriate decision maker. The example shows a handover problem. It does not imply that the adviser should approve the business’s program or that receiving professional advice proves the underlying process is working correctly.

Plan for changes and exit

Review whether the provider’s capacity and access remain suitable when the business changes. Record who receives urgent issues if the usual contact is absent. Agree how working records and unresolved actions return to the business when the engagement ends. Test that handover while the relationship is active. If the provider also performs customer checks, assess that arrangement under the separate CDD guidance. Good supplier oversight should make the work and its limits visible, while preserving the business’s own decisions and evidence.

Check performance against the task

Review a sample deliverable against the agreed task and evidence requirements. Ask whether the output can support a business decision and whether limitations are clear. Record material gaps and the response. This gives a concrete basis for improving the arrangement instead of relying only on the supplier’s reputation or a service-level summary.

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: Statutory CDD reliance arrangements; Selection of an independent evaluator.

Common AML/CTF terms