Can a single Risk Assessment and AML Program cover multiple offices in a Reporting Group?
Yes, a reporting group is set up under one lead entity, and the lead must develop a group-wide AML/CTF Program that apply across all member entities.
Yes - a reporting group is set up under one lead entity. Under the AML/CTF Act, the lead entity of a reporting group must develop a group-wide ML/TF risk assessment and group-wide AML/CTF policies that apply across all member entities.
A clarification on terminology first: a reporting group is made up of separate reporting entities (separate legal persons, typically related companies under common control, or unrelated firms that elect to join together).
If your firm operates from multiple offices under a single ABN, you're a single reporting entity — you don't form a reporting group at all, and you have one AML/CTF program covering all your offices by definition (although easyAML allows you to have segregated accounts if you want only certain teams to be able to see certain transaction - the CO must have access to all accounts/transactions).
In easyAML, this is operationalised through entity-level risk profiling within the group structure. Each member entity's specific risk factors — geographic exposure, customer mix, service mix, transaction patterns — feed into the consolidated group-wide risk assessment, so the assessment captures the diversity. The Compliance Officer can switch between member entities via the account selector to oversee operational activity, while the group-wide program and policies remain the single source of truth.