Five specialist services covering every stage of your compliance obligations under AUSTRAC's Tranche II reforms — designed to work together or independently, wherever you need us.
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 not only fails to protect your business — it signals to regulators that your compliance program lacks genuine commitment.
WilliamThomas&Co. conducts rigorous, business-specific ML/TF risk assessments that examine your client base, service types, transaction channels, and geographic exposures in detail. We produce assessments that are thorough, well-reasoned, and built to withstand scrutiny.
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 that meets your obligations and forms the foundation of your compliance 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 demands more genuine expertise, not less. A risk-based program requires real judgement — about your clients, your services, your risk exposure, and your controls. It cannot be downloaded from the internet or copied from a template.
WilliamThomas&Co. designs and implements tailored AML Programs that meet your obligations under the new framework — proportionate to your risk profile, practical for your team, and built to demonstrate genuine compliance rather than box-ticking.
This is not template work. It is professional advisory engagement — and the difference shows.
If you've done a risk assessment (or are about to) and need to turn it into a compliant AML Program under the new framework, this is the next step. We handle the complexity so you can focus on running your business.
"A tailored, risk-based AML Program — compliant with the new legislative framework, practical for your business, and genuinely yours."
Your legal obligations extend beyond having an AML/CTF program in place. Your staff must understand it, apply it, and know how to respond when something doesn't look right. Under the AML/CTF Act, staff training is a mandatory component of every regulated entity's program.
WilliamThomas&Co. delivers structured, role-appropriate training grounded in real-world scenarios relevant to your industry — covering customer due diligence, suspicious matter reporting, and your business's specific policies.
Available in-person or remotely, with full documentation for your compliance records.
Whether you have one employee or twenty, we tailor training to your team's size and roles. If it's just you, we'll make sure you know everything you need to. Delivered in a single session or across multiple dates.
"A team that understands the why behind compliance — with documented training records for your program."
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. conducts independent reviews assessing the adequacy of your risk assessment, the design and operational effectiveness of your policies, the quality of your training arrangements, and your overall compliance posture.
You receive a structured written report with clear findings and prioritised recommendations — conducted with the same rigour 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 prioritised recommendations — to the standard regulators expect."
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 access previously available only to large institutions with in-house compliance teams. Now available to you.
This suits businesses that want peace of mind without becoming compliance experts themselves. Arrangements start from as little as a few hours per month — you run your business, we keep an eye on your obligations.
"Senior compliance advisory support — structured around your business, available when you need it."