Uplifting a Growing Non-bank Lender’s AML/CTF Program

An Australian non-bank lender faced significant regulatory and operational challenges in its Anti-Money Laundering and Counter-Terrorism Financing (“AML”)(“CTF”) program ahead of AUSTRAC’s Tranche 2 reforms and expanded obligations. These pressures were exacerbated by manual processes and control weaknesses ahead of a planned business expansion. The client engaged FTI Consulting to review its AML/CTF framework and recommend targeted actions to strengthen and future-proof its compliance capability.

 

Our Impact

  • As a result of our review, the client identified critical execution gaps between documented policy and operational practice, including weak customer risk management capability, over-reliance on manual processes and unclear governance and assurance structures.
  • The remediation roadmap then addressed five key themes: priority control gaps, transition from manual to systematised controls, strengthened governance and accountability, policy operationalisation through detailed procedures and enhanced organisational capability with quality assurance.
  • Additionally, the client received more than 40 prioritised recommendations to address immediate regulatory compliance weaknesses, strengthen core controls and enhance governance and assurance capabilities.
  • The outputs of the review enabled the non-bank lender to proactively address regulatory compliance requirements, while building operational maturity necessary to support its planned business expansion through a phased uplift approach.

Our Role

  • Our financial services risk and compliance experts performed an independent review of the non-bank lender’s AML/CTF program across 17 distinct sub-scope areas.
  • FTI Consulting evaluated the client's readiness for AUSTRAC Tranche 2 regulatory reforms and assessed the control design and operating effectiveness of the AML/CTF program with consideration of planned business expansion.
  • The comprehensive review included documentation analysis, stakeholder interviews and workshops, sample testing of customer files and suspicious matter reports and assessment against current and proposed regulatory requirements.
  • Our experts produced a phased remediation roadmap to prioritise high risk recommendations while balancing resourcing and capacity.

Related Insights

Published

August 06, 2026

temp Key Contacts

Warren Dunn

Senior Managing Director, Head of Risk Advisory, Australia

Dylan Ryan

Senior Managing Director

Frank Colubriale

Senior Director

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