Can a customer edit the generated AML Program to reflect internal policies?
Not currently; the Program is generated from Risk Assessment answers to preserve the audit trail back to evidence, and internal-policy alignment is best handled through the RA inputs.
Today, no - the Program is generated from your Risk Assessment answers and isn't directly editable in-platform. This is by design: the auto-generation ties the Program back to evidence in the Risk Assessment, so an external auditor can trace each control to a corresponding input. Free-form editing would break that audit trail.
Workaround for internal-policy alignment (and the path most firms take):
- Use the Risk Assessment answers as the lever. The Program is shaped by how you answer the RA - if your internal policy is "we never accept cash", set that in the RA and it propagates into the Program. If your firm requires a higher-than-default review cadence for certain client types, set the corresponding risk inputs higher.
- For policies the RA doesn't capture cleanly, add an internal-policy supplement as a companion document maintained outside easyAML, and reference it from the relevant Program section. AUSTRAC accepts a Program backed by supplementary policies, provided the linkage is clear.
Roadmap. The platform is adding the ability to append firm-specific clauses to the generated Program (with the original auto-generated content untouched, and appended sections clearly marked). Expected late 2026.
See AUSTRAC's AML/CTF Program reform materials.