Four areas of support covering the key stages of your AML/CTF compliance obligations — available together or individually, wherever you need help.
A Money Laundering and Terrorism Financing risk assessment is the cornerstone of your obligations under the AML/CTF Act — and under AUSTRAC's Tranche II reforms, it is now a legal requirement for your business.
Getting it right matters. A superficial or generic risk assessment doesn't help you understand your actual exposure — and may not meet the standard AUSTRAC expects.
WilliamThomas&Co. supports you through a thorough, business-specific ML/TF risk assessment — examining your client base, services, transaction channels, and geographic exposures. You'll receive a clear, well-reasoned assessment to help you demonstrate compliance.
If you've been told your business needs a risk assessment and you're not sure what that involves, this is where we start. We guide you through the entire process — no prior compliance knowledge needed.
"A clear, documented ML/TF risk assessment to help you understand your obligations and form the foundation of your AML/CTF program."
From 31 March 2025, the AML/CTF framework moves to a single, consolidated AML Program — replacing the previous Part A and Part B structure for all regulated entities under Tranche I and Tranche II. The new framework is explicitly risk-based, meaning your program must reflect the actual risks your business faces, not a prescribed checklist.
This shift requires genuine thought — about your clients, your services, your risk exposure, and your controls. A risk-based program needs to reflect your actual business, not a generic template.
WilliamThomas&Co. helps you develop a draft AML Program under the new framework — proportionate to your risk profile, practical for your team, and prepared to help you demonstrate genuine compliance. The draft is yours to review, adapt, and incorporate into your business as part of meeting your own obligations.
This is not template work. It is considered, experienced support — and the difference shows.
If you've done a risk assessment (or are about to) and need help working through a draft AML Program under the new framework, this is the next step. We guide you through it so you can focus on running your business.
"A draft, risk-based AML Program — prepared for your review and use, structured to meet the new legislative framework, and genuinely reflecting your business."
Your AML/CTF program must be reviewed regularly — and that review must be independent. AUSTRAC expects genuine, arms-length evaluation. Self-assessment does not satisfy this requirement.
WilliamThomas&Co. provides independent reviews to help you assess the adequacy of your risk assessment, the design and operation of your policies, and your overall compliance posture.
You receive a structured written report with clear findings and prioritised recommendations — drawing on the same approach applied in regulated financial institutions.
If you already have a compliance program in place — built yourself, from a template, or with someone else — an independent review will tell you honestly whether it meets the standard AUSTRAC expects. No judgement. We're here to help you fix it if needed.
"A structured written report with clear findings and recommendations — to help you understand where your program stands."
Compliance is not a one-time event. Regulations are updated, businesses evolve, staff change, and new client relationships introduce new risks. Maintaining the integrity of your AML/CTF program requires ongoing attention.
WilliamThomas&Co. offers retained compliance support — whether for guidance on a specific client situation, help updating your program, or a standing arrangement for regular oversight.
The kind of experienced, accessible guidance that used to be hard to find for smaller businesses. Now available to you.
This suits businesses that want guidance available when they need it, without having to become compliance experts themselves. Arrangements start from as little as a few hours per month — you run your business, and we're there to help when questions arise.
"Experienced compliance guidance — structured around your business and available when you need it."