Uplifting a Growing Non-bank Lender’s AML/CTF Program
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2026年8月06日
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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.
相关服务
发布于
2026年8月06日
主要联络人
Senior Managing Director, Head of Risk Advisory, Australia
资深董事总经理
高级总监