Sole traders and micro-businesses can have one person performing all three governance roles — but they remain responsible for every duty.
Key concepts
One person, three hats
Owner / governing body
You approve the program and risk assessment.
Compliance officer
You run the program day-to-day.
Operator
You also deliver the designated service.
Proportionate, not minimal
AUSTRAC expects program rigour proportional to your size — but the obligations themselves don't shrink. Document everything, even when it's just you.