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

# Independent evaluation of the practice AML/CTF program

> A checklist for an independent evaluation of a legal practice AML/CTF program: who may evaluate it, what they must be given, who receives the written report, and how adverse findings are answered.

Canonical page: https://ailawframework.com/precedents/aml-ctf-the-practice-as-a-reporting-entity/independent-evaluation-preparation  
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 the practice is arranging or answering an independent evaluation of its AML/CTF program. It is not the ML/TF risk assessment record, and it is not the starter-kit adoption guide.

## 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 list documents already on the AML file and dates of earlier evaluations; the lawyer decides whether the evaluator is independent and how an adverse finding is answered.

**AI may:**

- List the risk assessment, the policies, and earlier evaluation reports that are already saved on the file
- Enter the date the written report was received and the date it was sent to the governing body

**AI must not:**

- Must not decide that an evaluator is independent or suitable
- Must not treat disagreement with a finding as a reason to skip the review the page requires
- Must not invent a qualification the page says is not mandatory

**The lawyer checks:**

- The policies state how independence and suitability are decided, and the evaluator is not the compliance officer or a member of the compliance team
- The written report goes to the governing body and to the senior manager who approves the program
- Any update to the risk assessment or the policies is documented within 14 days after the update is made

## Authorities

- [AUSTRAC, Step 5: Conduct an independent evaluation, last updated 31 March 2026: sections 26F and 26H of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, section 116, and Rules sections 5-10, 5-1, 5-4 and 5-15](https://www.austrac.gov.au/industry-and-business/obligations-and-guidance/your-amlctf-program/develop-your-amlctf-programs/step-5-conduct-independent-evaluation)

## 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/independent-evaluation-preparation 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.*