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For accounting practices

Your AML/CTF program, drafted with you. No fee.

We arrange finance. We would like to be the people you think of when a client of yours needs it. The program is not conditional on that.

Ask about your program Client finance enquiry

Client finance: Phil Riches, 0418 204 304

Who this is for

Businesses providing designated accounting services came under AUSTRAC regulation on 1 July 2026. AUSTRAC regulates the services you provide, not your job title. Its website sets out which services are designated. If you are unsure whether you are in scope, check there or with your own adviser.

What we draft with you

A written AML/CTF program for your practice, covering:

  • Your AUSTRAC enrolment position
  • A risk assessment specific to your practice: client types, services, delivery channels and jurisdictions
  • Policies that respond to that risk assessment
  • Your named AML/CTF compliance officer
  • Customer due diligence procedures
  • Sanctions screening
  • Suspicious matter reporting, and any threshold reporting that applies to you
  • Record keeping arrangements
  • A staff training plan

What it costs

  • Drafting the program: no charge
  • Identity checks, if you run them through FileCheck, at its published prices: $15 + GST per individual and $35 + GST per business, on top of a FileCheck subscription from $49 a month + GST
  • Month to month. No lock-in.

What we are not doing

  • We are not lawyers and this is not legal advice. Your own legal review before you adopt the program is encouraged.
  • Your practice remains the reporting entity. We do not take on any of your obligations.
  • The program is yours. You review it, adopt it, sign it off and operate it.
  • We do not audit your existing compliance or certify anything to AUSTRAC.

Why we do it at no charge

We arrange finance, and we would like to be the broker you think of when a client needs it. There is no requirement to refer anyone, and the program is not conditional on it.

If we do set up a referral arrangement later, it is documented separately. There is a short disclosure you give your client when you refer them, and we provide the exact wording.

What your client sees

A routine identity verification, the same for everyone. They are asked to confirm their identity details.

Finance for your clients

Commercial and construction finance since 2004: medical suites, childcare centres, business premises and builds. Plus home loans, self-employed lending and refinancing.

Who you deal with

Virginia Graham drafts the program. Model Mortgages Pty Ltd holds its own Australian Credit Licence, 387460, and is an AFCA member, 44337. Phil Riches looks after client finance referrals.

Questions practices ask

Do we stay the reporting entity?

Yes. The program is drafted with you and adopted by you. Your obligations stay with your practice.

Do we have to refer clients to you?

No. The program is not conditional on referrals.

What do we have to disclose?

Only if a referral arrangement is set up. It is documented separately, and you give your client a short disclosure at the time you refer. We provide the wording.

What happens to the information we share?

It stays confidential and is used only to draft your program. To start, we need the types of engagements your practice provides. No client names.

What if we already have a program?

Then you may not need this. We do not audit or replace an existing program.

Start with your engagement types

Tell us the kinds of work your practice does. No client names. We will come back to you about drafting your program.

Ask about your programBook a call