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Our audit team undertakes the complete range of audits required of Australian accounting laws to help you to help you meet obligations or fulfil best practice procedures.
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Podcast The future of auditing: technology and AI

In this episode, Partner and Head of Digital Assurance Liam Te-Wierik explores how technology is assisting auditors, the guardrails to be considered when using these tools and his thoughts on future trends for the auditing profession.

Liam Te-Wierik

| 21 min listen | 09 Apr 2025

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Client Alert Northern Territory delivers first budget under Country Liberal Party

Alongside Chief Minister Lia Finocchiaro, Treasurer Bill Yan focused on reducing crime and increasing public service employee costs in supporting hospital and correction services.

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Insight Strengthening ADIs through better governance and strategy

ADIs are navigating regulatory reform, digital transformation, and rising fraud risks by strengthening governance, modernising infrastructure, and aligning strategy with compliance to drive resilience and long-term value.

| 8 min read | 08 May 2025

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Insight Post-acquisition disputes: common issues and mitigation opportunities

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| 5 min read | 09 Apr 2025

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Podcast Dealtracker 2025: The landscape of Australian deals

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Jannaya James

| 16 min listen | 07 May 2025

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| 5 min read | 18 Mar 2025

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| 5 min read | 22 Oct 2024

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Does your company need a health check? Grant Thornton’s expert team can help you get to the heart of your issues to drive sustainable growth.
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We provide corporate simplification and managed wind-down advice to help streamline and further improve your business.
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We work closely with clients and lenders to provide holistic debt advisory services so you can raise or manage existing debt to meet your strategic goals.

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Insight The rise in retail insolvencies

| 5 min read | 22 Oct 2024

Business services

We work with private businesses across Australia – and internationals looking to Australia for their investments and operations – on all accounting and...

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Business planning & strategy
Our clients can access business planning and strategy advice through our value add business strategy sessions.
Private business company secretarial services
We provide company secretarial services and expert advice for private businesses on all company secretarial matters.
Outsourced accounting services
We act as a third-party partner to international businesses looking to invest in Australia on your day-to-day finance and accounting needs.
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We provide SMSF advisory services across all aspects of superannuation and associated tax laws to help you protect and grow your wealth.
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Whether you’re opening a business for the first time or looking to expand, Australia is one of the most attractive business locations in the world with a relatively deregulated and open economy.

Matt Adam-Smith

| 01 May 2025

Environmental, Social and Governance (ESG) and Sustainability

Having a considered and informed ESG response has never been more important for all organisations as we are seeing awareness of the elements of ESG continue to...

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ESG, sustainability and climate reporting
There is a growing demand for organisations to provide transparency on their commitment to sustainability and disclosure of the nonfinancial impacts of their business activities. Commonly, the responsibility for sustainability and ESG reporting is landing with CFOs and finance teams, requiring a reassessment of a range of reporting processes and controls.
ESG, sustainability and climate advisory
With the ESG and sustainability landscape continuing to evolve, we are focussed on helping your business to understand what ESG and sustainability represents and the opportunities and challenges it can provide.
ESG, sustainability and climate reporting assurance
As the demand for organisations to prepare information in relation to ESG & sustainability continues to increase, through changes in regulatory requirements or stakeholder expectations, there is a growing need for assurance over the information prepared.
ESG and sustainability due diligence
As environmental, social, and governance (ESG) considerations become increasingly pivotal for dealmakers in Australia, it is important for investors to feel confident in assessing transactions through an ESG lens.

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Explore the benefits of sustainability reporting, from increased revenue and access to grants, to improved share price and talent retention.

| 6 min read | 01 May 2025

Consulting

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Management consulting
Our management consulting services team helps you to plan and implement the right strategy to deliver sustainable growth.
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We provide financial consulting services to keep your business running so you focus on your clients and reaching strategic goals.

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Insight Could ‘gamification’ encourage the Rising Generation in family business?

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Asia

The growth gateway

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China practice
The investment opportunities between Australia and China are well established yet, in recent years, have also diversified.
Japan practice
The trading partnership between Japan and Australia is long-standing and increasingly important to both countries’ economies.
India practice
It’s an exciting time for Indian and Australian businesses looking to each jurisdiction as part of their growth ambitions.
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Vietnam practice
Investment and business opportunities in Vietnam are expanding rapidly, driven by new markets, diverse industries, and Vietnam's growing role in export manufacturing, foreign investment, and strong domestic demand.

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Report Doing business in Australia

Whether you’re opening a business for the first time or looking to expand, Australia is one of the most attractive business locations in the world with a relatively deregulated and open economy.

Matt Adam-Smith

| 01 May 2025

Industries

Agribusiness, Food & Beverage

Supporting the growth of ‘Australian Made’ in today’s markets

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Energy & Resources

From an active natural resources M&A market, a growing energy and renewable energy market, to new technologies and export and trade agreements – we have the...

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Renewable Energy
Transformation through energy transition

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Insight Impact of retaliatory tariffs on Australian and New Zealand exporters

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Professional Services

Setting Australia’s knowledge powerhouse up for success

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Our aim is to help you find a better, simpler, more efficient, and more profitable way of doing things to keep your business safe and help you grow.

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INSIGHT

The elements of an AML/CTF Program

By:

Neil Jeans,

Katherine Shamai

19 Feb 20254 min read

Australia has commenced reforming its Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) regime including the ‘Tranche 2’ reforms, which expand AML/CTF compliance to apply to additional professions including lawyers, accountants, real estate agents, property developers, and precious stone dealers.

An Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) program is essential to support organisations complying with AML/CTF obligations and requirements.

Under the AML/CTF Act 2024, all reporting entities must have (before providing designated services) and maintain (throughout the time they are providing designated services) an AML/CTF Program that appropriately identifies, mitigates, and manages their ML/TF risk and addresses the AML/CTF system and control requirements set out in the AML/CTF Rules.

AML/CTF program documents

Under the AML/CTF Act, an AML/CTF program comprises several key documents, each crucial in ensuring compliance with revised AML/CTF obligations.

Risk assessment

This document sets out the systematic and structured identification of ML/TF risks, an assessment of the likelihood and impact of those risks, and the documentation of the risk assessment process.

Forms the foundation of the AML/CTF program by identifying and evaluating the specific risks faced by the reporting entity and guiding the development of tailored AML/CTF policies and procedures.

The risk assessment informs all other documents, ensuring the AML/CTF program is risk-based and focused on the most significant threats.

AML/CTF policy

This document outlines the reporting entity's approach to managing and mitigating identified ML/TF risks and ensuring compliance with the general requirements in the AML/CTF Act and AML/CTF Rules.

The AML/CTF policies must be developed based on the risk assessment and provide the framework for the procedures manual.

Procedures manual

This document provides detailed instructions on implementing AML/CTF policies, ensuring consistency and effectiveness in applying AML/CTF measures.

The procedures manual operationalises the policies and is informed by the risk assessment by providing detailed procedural guidance to ensure consistency and effectiveness in applying AML/CTF measures.

The procedures manual provides practical guidance for staff on how to comply with AML/CTF obligations.

Next steps

To address the AML/CTF program requirements under the AML/CTF Act, new reporting entities should follow a structured, step-by-step approach:

1 - Conduct a comprehensive risk assessment

Develop a detailed risk assessment document that evaluates the specific ML and TF risks faced, including consideration of proliferation financing (PF) risks.

2 - Develop AML/CTF policy

AML/CTF policies are required to address the identified risks and comply with the AML/CTF Act requirements. The policies must align with the outcomes-based framework and adequately cover ML/TF/PF risks.

3 - Create a detailed procedures manual

Establish procedures that provide detailed instructions on implementing the AML/CTF policies set out in the AML/CTF policy, ensuring the manual promotes consistency and effectiveness in applying AML/CTF measures.

4 - Stay informed

Monitor for additional AML/CTF Rule requirements and guidance AUSTRAC provides. It is understood the AML/CTF Rules will be published around June 2025, with core Guidance published by AUSTRAC in August 2025 and Tranche 2 specific Guidance by December 2025.

Civil penalty provisions

The AML/CTF Act introduces new civil penalty provisions related to the development and maintenance of an AML/CTF program, increasing the regulatory risk related to non-compliance. These include civil penalty provisions for failure to document an AML/CTF program, failure of the AML/CTF Program to cover mandated requirements, and failure to notify the governing body of AML/CTF program changes.

We are here to help

Although the new AML/CTF requirements won't be enforced until 2026, it is vital to start planning and preparing for compliance with AML/CTF requirements now. With a short lead time to compliance and limited AML/CTF experts across Australia, demand will only continue to increase as the compliance date approaches. If you would like to discuss any of the above with one of our AML/CTF specialists, please reach out.

Learn more about how our Anti-Money Laundering reforms services can help you

Visit our Anti-Money Laundering reforms page