Governance is how you manage decisions and check compliance. Three roles every business needs.
Key concepts
The three governance roles
Governing body
Approves the AML/CTF program and risk assessment. Receives at least annual AMLCO reports.
AML/CTF compliance officer
Eligible person with authority to act. Reports to the governing body. Notify AUSTRAC within 14 days of appointment.
Senior managers
Implement the program day-to-day. Allocate resources and ensure escalation paths work.
Checklist
Things you must document
- Roles, decision rights, reporting cadence.
- AMLCO eligibility — Australian resident, fit & proper, sufficient seniority.
- Senior-management approval of policies and risk assessment.
- Annual AMLCO report to the governing body.