AML/CTF Compliance — Pubs & Clubs

AML/CTF Program Review

Would the Program sitting in your drawer survive a specialist’s eye? It is the question every board should answer before AUSTRAC asks it.

A desk review of your written AML/CTF Program and risk assessments — assessed line-by-line against the reformed AML/CTF Act, the AML/CTF Rules 2025, the Transitional Rules and current AUSTRAC guidance.

Request a Program Review⟶ Looking for an Independent Evaluation?⟶

Scope of work

What we review

The Program manual, every appendix and SOP, your risk assessments and your customer-facing and staff forms — assessed line-by-line against the reformed AML/CTF Act, the AML/CTF Rules 2025, the Transitional Rules and current AUSTRAC guidance.

Component 1

Your risk assessment(s)

The ML/TF/PF risk assessment for each venue — reviewed for completeness, currency and compliance.

Component 2

Your written Program

The Program manual, every appendix and SOP, and your customer-facing and staff forms.

We identify compliance gaps, legacy pre-reform content, drafting defects and internal inconsistencies — and give you prioritised, actionable recommendations, each classified honestly as a legal requirement or a regulator expectation.

Important: a Program Review is not the independent evaluation the Act requires (AML/CTF Act s 26F(4)(f); AML/CTF Rules r 5-10) and involves no interviews, sampling or venue fieldwork — it is the right first step before one, and your clearest map of what to fix first. Learn about Independent Evaluations →

Deliverable

What you receive

A written Program Review report with findings cited to the exact provision.

A prioritised recommendations schedule — what to fix first, and why.

Presented to your management team in person, with Elite Legal available by Teams for your Board’s questions.

A Program Review does not include interviews, transaction analysis, detailed remediation specifications or operational effectiveness testing — those belong to the Independent Evaluation.

Indicative timetable

Four weeks, start to finish

Week 1

Meet & greet; documentation upload to a secure portal.

Weeks 2–3

Desktop analysis of your risk assessment(s) and Program policies, procedures and controls.

Week 4

Report preparation and presentation to your management team (by Zoom or Teams).

Which one do you need?

Review or Evaluation?

This page

Program Review

Desk review of your written Program and risk assessments
Line-by-line against the reformed Act, Rules and AUSTRAC guidance
Prioritised, cited recommendations — your map of what to fix first
No interviews, sampling or venue fieldwork
The right first step before a statutory evaluation

Request a review⟶

The statutory requirement

Independent Evaluation

The regular, independent evaluation the Act requires (s 26F(4)(f); r 5-10)
Compliance AND proper implementation
Transaction Analysis and Staff Interviews
A board-ready report the Directors can read and adopt
Evidence of your Board’s reasonable steps (s 26H)

Independent Evaluations⟶

Request a Program Review

Would your Program survive a specialist’s eye?

Send us your details and we’ll come back to you about a Program Review for your venue — confidential and no-obligation.

✆02 8515 8062 ✉info@elitelegal.com.au ⚲Level 13, 111 Elizabeth St, Sydney

This page provides general information only and does not constitute legal advice.

AML/CTF Program Review

What we review

Your risk assessment(s)

Your written Program

What you receive

Four weeks, start to finish

Review or Evaluation?

Program Review

Independent Evaluation

Would your Program survive a specialist’s eye?

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