These are the core elements that help establish a sound and defensible compliance baseline. If you are a Tranche 2 entity or are already captured under AUSRTAC reporting requirements, then this is the minimum standard required for compliance that you must be able to articulate through evidence
Enterprise-wide assessment of AML, financial crime, and corruption risks across your business, customers, channels, and services
Design or uplift of AML/CTF policies, procedures, controls, and governance settings tailored to your operating model.
Risk-based onboarding, verification, beneficial ownership review, and escalation pathways for higher-risk customers.
Stronger review measures for complex customers, unusual structures, high-risk jurisdictions, and elevated matters.
Transaction monitoring, red-flag identification, behavioural review, and internal escalation processes.
Sanctions, watchlist, politically exposed person, and adverse media screening aligned to your risk profile.
Clear, usable documentation that supports consistent decision-making and practical implementation.
Role-based training to help boards, executives, and staff understand obligations and apply controls properly.
Objective health checks and assurance reviews to test whether your program is working in practice.
Frameworks and controls to prevent, detect, and respond to bribery, corruption, conflicts, and improper conduct.
Due diligence and oversight for brokers, introducers, agents, vendors, contractors, and other external relationships.
Clear ownership of risk, reporting lines, committee oversight, and defined responsibilities across the business.
Practical measures to strengthen internal integrity, reduce misconduct risk, and improve organisational discipline.
Structured support for internal concerns, suspicious matters, control failures, fraud indicators, or misconduct issues.
Better recordkeeping, evidence capture, documentation discipline, and decision trails for scrutiny or review.
Meaningful reporting that gives leaders visibility of risks, controls, incidents, and improvement priorities.
Preparation for regulatory review, external scrutiny, remediation activity, or formal program uplift.
Improving how compliance tasks, approvals, monitoring, alerts, and recordkeeping work across the business.
Supporting ethical conduct through leadership expectations, reporting pathways, and stronger integrity settings.
A staged uplift approach that strengthens maturity, capability, and control over time.
Minimum viable compliance may help meet basic obligations. Stronger financial crime and anti-bribery and corruption program components help businesses go further by improving governance, reducing unmanaged exposure, strengthening decision-making, and supporting more resilient performance.