Independent evaluation every three years for a two-person firm

People search “AML independent evaluation” when a two-partner firm wants the partner who drafted the program to sign the evaluation as well. Checked against AUSTRAC's independent evaluation step on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. Writing the program is a different job, on the AML/CTF program for Tranche 2. Whether a sole trader can be their own officer is can a sole trader be their own compliance officer. The sector map is /tranche-2.

Why the author of the program cannot mark it

In a two-person firm the same two people usually wrote the risk assessment, approved the policies, and run the files. An independent evaluation is a further look by someone free of that work. The partner who designed the program is not free of it, and neither is the compliance officer who maintains it. A read-through by the author is an internal review with a larger name.

• Three years is the longest gap. The policies set the frequency, and it must suit the firm. Write down why you chose it. Do not treat three years as a date you must wait out.
• The writer is out. The partner who built the risk assessment or the policies does not evaluate that work.
• The officer is out. The compliance officer maintains the program. Holding the role is the conflict, even when the firm is two people.
• No mandatory certificate. The evaluator still needs to know the obligations that apply to a firm like yours, or the report will not test the program.

Who can sign it in a firm of two

A two-partner office rarely has an internal audit team, so the suitable person is usually outside the firm and was not hired to draft the program. The first evaluation can fall later than a neat three-year anniversary because transitional rules stagger that first date. This page does not copy that timetable.

Where the three-year page stops

This page is the three-year evaluation in a two-person firm. It is not how you write the program, and it is not who may be the officer. Those questions sit on the AML/CTF program for Tranche 2 and can a sole trader be their own compliance officer.

What the client pays

On FreeAML the firm suite is A$0. The firm emails the client a link. Verification is client-pays. On the public list a personal KYC check is A$20 and a company or trust KYB check is A$40. Use KYB when the customer is a company or a trust. The evaluation is not a customer check, and a file the evaluator says is still unverified is a separate client-pays check. Confirm the live amounts on FreeAML pricing. FreeAML does not appoint your evaluator or treat your own review as the independent evaluation.

Frequently Asked Questions