---
title: "First independent evaluation deadline for the practice"
url: "https://ailawframework.com/precedents/aml-ctf-the-practice-as-a-reporting-entity/first-independent-evaluation-deadline"
type: "precedent"
site: "AI Law Framework"
id: "a52ob-first-independent-evaluation-deadline"
area_id: "A52OB"
kind: "checklist"
ai_level: "yellow"
version: 1
task_ids: ["A52OB-X20260927-2"]
law_stated_as_at: "2026-10-22"
---

# First independent evaluation deadline for the practice

> A worksheet for the first independent evaluation date on AUSTRAC's transitional-rules page: the four AUSTRAC account-number patterns, and the later-of rule for an existing reporting entity.

Canonical page: https://ailawframework.com/precedents/aml-ctf-the-practice-as-a-reporting-entity/first-independent-evaluation-deadline  
Law stated as at: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

- Kind: Checklist. Steps or checks to work through and tick off.
- Practice area: [AML/CTF — the practice as a reporting entity](https://ailawframework.com/precedents/aml-ctf-the-practice-as-a-reporting-entity.md)
- Jurisdictions: Australia
- AI level: Yellow. You and the tool draft together, with you directing. You check every statement you rely on.
- Law stated as at: 2026-10-22
- Status: Maintained. Checked on 2026-10-22 against the authority it cites, for Australia.

## When to use it

Use when setting the date of the practice's first independent evaluation under the Anti-Money Laundering and Counter-Terrorism Financing Transitional Rules 2026. It does not replace the evaluation checklist or the three-year frequency in the policies.

## Used for these tasks

- [Build the practice's risk assessment and AML/CTF policies](https://ailawframework.com/obligations/aml-ctf-the-practice-as-a-reporting-entity/build-the-practice-s-risk-assessment-and-aml-ctf-policies.md)

## How AI may be used

AI may read the last two digits of an account number the lawyer has entered and point to the matching row; the lawyer decides which limb of the transitional page applies.

**AI may:**

- Place the last two digits of the AUSTRAC account number into the four-row table
- Enter the date of the most recent pre-reform independent review if the file already records it

**AI must not:**

- Must not choose a deadline when the account number or the enrolment facts are missing
- Must not apply the existing-entity date to a practice that was not enrolled on 30 March 2026
- Must not treat the three-year minimum as a substitute for the first-date table

**The lawyer checks:**

- The limb is recorded as newly regulated, previously item 54 only, existing entity, or none of those
- The date matches the digit pattern or the later-of rule on the page, and no other date is invented
- The policies are updated so the evaluation schedule states the date the lawyer has accepted

## Authorities

- [AUSTRAC, AML/CTF transitional rules 2026, last updated 2 April 2026, Part 7: staggered initial independent evaluations](https://www.austrac.gov.au/about-us/legislation/updates-legislation/amlctf-transitional-rules-2026)

## Full text and drafting notes

The full text and the drafting notes are not part of this public page. Signed-in firm accounts can read them at https://ailawframework.com/precedents/aml-ctf-the-practice-as-a-reporting-entity/first-independent-evaluation-deadline and through the signed-in MCP connector https://ailawframework.com/mcp/firm.

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*