AML Program Independent Evaluation

You already have an AML/CTF Program. An independent evaluation confirms it's still fit for purpose — and specifically, whether it's aligned to the 2026 reforms. Showing guidance for Real Estate Agents.

Independent Evaluation

An Independent, Objective Assessment

AUSTRAC guidance recommends periodic independent reviews of both the design and operational effectiveness of your AML/CTF Program. Our evaluation — conducted by someone outside your organisation — gives you a clear, evidence-based report with actionable recommendations.

Design Evaluation

Focused specifically on whether your AML/CTF Program's design — risk assessment, policy, procedures, and governance — aligns to the 2026 AML/CTF reform obligations.

Program design reviewed against 2026 reform requirements
ML/TF/PF risk assessment review
Gap analysis & recommendations report
12 months ongoing support

Request a Design Evaluation

Full Independent Review

Full Evaluation

The complete periodic independent review AUSTRAC guidance recommends — covering both program design and operational effectiveness in practice.

Design assessment (as above)
Operational effectiveness testing
ML/TF/PF risk assessment review
Gap analysis & recommendations report
12 months ongoing support

Request a Full Evaluation

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The 2026 Reforms

What's Changing for Existing Entities — Real Estate Agents

Changes to AML/CTF obligations start on 31 March 2026 for existing reporting entities (threshold transaction and suspicious matter reporting stay on the current rules until the transition ends on 30 March 2029). Key changes include:

A more explicit risk-based approach to your AML/CTF Program
Designated Business Groups replaced by "reporting groups"
Updated customer due diligence requirements, including a new $5,000 cash threshold
Updated tipping-off provisions
The Travel Rule replacing IFTI reporting for value transfers

For Real Estate Agents

Property settlements often involve higher-value, time-pressured transactions, so the reforms' updated customer due diligence requirements are worth reviewing closely — particularly how your agency verifies funds and beneficial ownership on larger sales.

What You Receive

Evaluation Report

A clear, structured report detailing findings against each requirement.

Gap Analysis

Identification of gaps, weaknesses, or areas of non-compliance.

Recommendations

Practical, prioritised recommendations to address findings — remediation work can be quoted separately if you'd like us to implement them.

Risk Assessment Review

Assessment of whether your risk assessment remains current and fit for purpose.

12 Months Support

Ongoing support to help you interpret findings and maintain compliance.