Outsourcing CDD: you stay liable

People search “outsource AML compliance Australia” when a two-partner firm wants a consultant to 'take AML off our hands', including the enrolment and the reports. Checked against AUSTRAC's obligations and compliance page on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. What a check actually returns is what an AML check covers. The officer who still owns the program is the AUSTRAC compliance officer. The sector map is /tranche-2.

Tasks move. The reporting entity does not.

Outsourcing is attractive in a two-partner firm because nobody wants a second job. A provider can send the link, match the identity, and hand back a result your staff can file. That is a task. The obligation to have a program, to apply it, and to report when the law requires it, stays with the firm that provides the designated service.

Put the arrangement in the program in words a new clerk can follow. Who sends the link, who reads the result, who may still act if the result is incomplete, and who tells the compliance officer. A verbal 'the consultant handles AML' is how the firm discovers, on a bad file, that nobody lodged anything. The provider is not your enrolment and is not your officer.

• Keep enrolment. The business enrols. A consultant can sit with you while you do it. They are not the reporting entity.
• Keep the program approval. Someone outside can draft. A partner still approves. An unapproved draft is not a program.
• Keep the reports. Suspicious matters, and any other report the firm must make, are the firm's. Do not assume the provider filed them.
• Keep a named officer. Outsourcing the check does not abolish the compliance officer. The role still needs authority to pause a matter.

What a provider can hold, and what it cannot

Where the outsourcing page stops

This page is the liability that stays. It is not a description of what a check contains, and it is not the officer's job description. Those are what an AML check covers and the AUSTRAC 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. Paying a provider to help does not move the check off client-pays, and it does not make the provider the reporting entity. Confirm the live amounts on FreeAML pricing. FreeAML does not accept your liability or enrol, report, or approve the program for you.

Frequently Asked Questions