Outsourcing and Support

Many operational aspects of your AML/CTF compliance can be outsourced to specialized service providers, including:

Customer identification and verification: Using third-party identity verification (VerifiMe) platforms or services to conduct KYC/KYB checks.

Sanctions and PEP screening: Engaging vendors (VerifiMe) who provide screening services against current sanctions lists and PEP databases.

Transaction monitoring and ongoing customer due diligence: Utilizing software or services that monitor transactions for suspicious patterns, unusual activity, or anomalies as part of your ongoing customer due diligence (OCDD) obligations.

Report preparation and lodgment: Using compliance service providers to prepare and submit reports to AUSTRAC.

Employee training: Engaging external trainers or using e-learning platforms for AML/CTF education.

Independent audits and testing: Contracting specialists to conduct regular independent reviews of your program's effectiveness. Note: The reviewer must not have been involved in designing or implementing your AML/CTF policy or the Business-Wide Risk Assessment (BWRA), though the AML/CTF Compliance Officer is excluded from this restriction.

You cannot outsource overall accountability and certain core obligations. Your business remains ultimately responsible for compliance. Your organization must conduct its own Business-Wide Risk Assessment (BWRA), you must still appoint an AML/CTF Compliance Officer (AMLCO) within your organization, your board or senior management must adopt your AML/CTF Program, and you retain responsibility for ensuring outsourced services are performed effectively and meet regulatory requirements. When outsourcing, ensure you have appropriate contractual arrangements, oversight mechanisms, and regular reviews of provider performance.
​
​
​Disclaimer: This document provides general information and is not legal advice. Consult legal advisors and AUSTRAC guidance when developing your compliance framework.

Visit: www.austrac.gov.au