Can a firm upload its own externally-drafted AML Program?
Externally drafted Programs cannot replace the platform's because the Program engine actively drives risk ratings, transaction routing, training and reporting workflows.
It's increasingly common for firms - particularly larger ones or those with in-house compliance expertise - to have drafted their AML/CTF Program with the help of an external compliance consultant or industry advisor. That's a legitimate path and a sign of good preparation.
The practical reality with easyAML is that the platform's Program engine isn't a passive document store. It actively drives risk ratings, transaction routing, training requirements and reporting workflows. A document drafted outside the platform can't simply be uploaded and used in place of easyAML's Program - the engine needs the underlying inputs to produce consistent outputs across the rest of the platform.
Two practical paths forward:
1. Use easyAML for execution while aligning the Risk Assessment inputs to mirror your existing Program. The Risk Assessment inside easyAML can be configured to produce the same risk profile and treatment that your external Program describes. You keep the framework you've already invested in, and easyAML drives the day-to-day workflow underneath it.
2. Transition fully to easyAML's Program. The platform's Program is built around AUSTRAC's framework and is updated continually as guidance evolves. For most firms, this is the lower-maintenance long-term option - there's no external document to update separately when AUSTRAC publishes new guidance.
Either approach works. The choice usually comes down to how much you've invested in your external Program and whether you want to maintain it independently going forward.
No - third-party AML programs cannot replace the easyAML-generated program. The firm can still use easyAML for KYC/KYB, but transaction risk ratings are driven by easyAML's program. Workaround: configure the easyAML Risk Assessment to mirror the external program's risk profile so the same operational outcomes apply.