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Can one CO oversee multiple companies (e.g. a director across brands)?

Yes, a single Compliance Officer can cover multiple entities provided they understand the AML risk profile in each business and have sufficient authority to enforce compliance.

A single Compliance Officer can be appointed across multiple entities, provided they genuinely understand the AML risk profile in each business and have sufficient authority to enforce compliance across all of them.

This is a common pattern in:

  • Real estate franchise groups where one CO covers several franchisee offices under a common operating model.
  • Multi-disciplinary firms where one CO covers the legal arm, the conveyancing arm and the trust services arm.
  • Family business groups where the same principal director runs multiple related businesses under one ownership group.

What AUSTRAC expects: the CO must be a fit-and-proper person, must have management-level authority in each entity, must be Australian-resident where designated services are provided locally, and must have adequate resources to actually do the work for all the entities they cover. A CO stretched thin across 20 unrelated entities probably can't satisfy the resources test; one covering 3–4 closely-related entities usually can.

In easyAML, the same CO user account can be linked to multiple entities via the multi-entity switching mechanism above. The CO retains accountability separately for each entity - separate Risk Assessments, separate Programs, separate training records (where required), separate reporting.

See AUSTRAC's AML/CTF Program reform materials for the CO appointment framework.

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