AttestZ AML Evaluation

Independent evaluation, on a record you can check

Every AML/CTF program must be independently evaluated at least once every three years, by someone independent of the program itself — on AUSTRAC's staggered timetable, with early evaluation encouraged. AttestZ never writes AML/CTF programs. We evaluate them.

Who this is for

Existing reporting entities. The reforms replaced the independent review of Part A of your program with an independent evaluation of the whole AML/CTF program. If you were enrolled on 30 March 2026 and had a Part A review by then, your first evaluation is due before 31 March 2027, or four years after your last Part A review if that is later (AML/CTF Transitional Rules 2026, s 16).

It is offered through independent evaluators: a named evaluator of record runs the evaluation on AttestZ and signs the opinion. Businesses newly regulated from 1 July 2026 under the Tranche 2 reforms have later first deadlines, from 30 June 2029 to 31 December 2030.

What the law requires

An independent evaluation must cover three things: whether your risk assessment reflects the business as it actually operates; whether your policies are designed to meet the requirements; and testing — whether risk was actually identified, mitigated and managed, and the policies actually followed. The result goes to your governing body. The evaluator must be independent of the work being evaluated — not your compliance officer, not a member of your compliance team — and must have AML/CTF knowledge. No licence or accreditation is legally required, but a real evaluation still needs a name behind the opinion.

How AttestZ evaluates

A named evaluator of record — independent of your program, never a person who helped write it — runs the evaluation through AttestZ's own hash-chained record, the same record that carries AttestZ's other products. Every piece of evidence you supply is hashed on receipt, never held longer than the evaluation needs. The sample of files tested is drawn with a seed written to the record before selection — so the sample can never be picked to favour a result. Every test outcome, every finding, and the report itself is appended to a verifiable record, checkable by a standalone verifier without calling AttestZ.

AttestZ prepares the evaluation; the evaluator of record signs the opinion. AttestZ never writes AML/CTF programs, and a client who asks for help writing one is told we can then no longer evaluate it — that is the independence AUSTRAC requires, applied literally.


AttestZ AML Evaluation is available from November. Pricing is a fixed fee per evaluation.

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If you are an independent evaluator, or a reporting entity due its first evaluation, write to us and we'll be in touch when evaluations open.

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