The reformed AML/CTF regime sets out three governance roles: the governing body, senior managers, and the AML/CTF compliance officer. In the coming weeks BPSi Verify will reflect these roles in who can do what, so your records show each decision was made by the right person.
What's changing
Admin — running the firm, and senior-manager approvals
- Manages your firm's account and users.
- Gives the approvals the regime reserves to senior managers: approving your AML/CTF program and ML/TF risk assessment, and approving taking on a foreign PEP client (and a high-risk domestic or international-organisation PEP). Each approval is recorded as given in that capacity.
Compliance — compliance decisions
- A separate permission for the compliance work itself: confirming risk ratings, enhanced due diligence, screening decisions, periodic reviews and suspicious matter reports.
- More than one person can hold it — for example a deputy or a compliance team.
Your designated AML/CTF compliance officer
- Each firm names exactly one designated officer: the person notified to AUSTRAC as your AML/CTF compliance officer.
- They must hold the Compliance permission and be at management level, fit and proper, and resident in Australia. BPSi Verify will record that eligibility and a date to reassess it.
- If the designated officer changes, you'll be asked to name the replacement — and reminded to notify AUSTRAC.
In a small practice
One person can hold every role. A sole practitioner is the admin, holds Compliance and is the designated officer — nothing extra to do beyond confirming it.
What happens on the day
- Nobody loses access. Every current admin keeps the Compliance permission.
An alert to confirm your designated compliance officer
After the change, admins will see an alert in BPSi Verify asking for the name of your firm's designated AML/CTF compliance officer:
- If you're the only admin, you'll be asked to confirm that you are the designated officer.
- If your firm has several admins, you'll be asked to nominate one person — they must hold the Compliance permission.
- You'll also confirm the officer is at management level, fit and proper, and resident in Australia, and BPSi Verify records a date to review that confirmation (usually 12 months).
- The alert stays until it's done, but it won't stop you working. It comes back when the confirmation is due for review, or if your designated officer leaves or changes — in which case you'll also be reminded to notify AUSTRAC.
What to do now
Decide who your designated AML/CTF compliance officer is, so you can confirm their name as soon as the alert appears — and make sure your AML/CTF program records them.
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