Does the outsource option mean the firm is no longer the reporting entity?
No, the firm remains the reporting entity under AUSTRAC's framework regardless of who handles the day-to-day prep work; AML on Demand offloads operational workload only.
Your firm remains the reporting entity and retains their obligations under AUSTRAC's framework regardless of who handles the day-to-day prep work. AML on Demand takes the operational workload off your desk; it doesn't change where the legal obligation sits.
What this means in practice
- The AML/CTF Program, Risk Assessment, ongoing staff training (for staff still in roles), reporting obligations (SMR, TTR and IFTI), and the 3-yearly independent evaluation all remain your firm's responsibility. The platform supports each of these, but the obligation to have them, maintain them, and report under them sits with you.
- AUSTRAC enrolment stays in your firm's name. Your firm is the entity providing the designated service, so it's your firm that's enrolled, your firm that's named on the compliance report, and your firm that's accountable to the regulator.
- The CDD records belong to your firm. They're held in the easyAML platform on your behalf — exactly the same arrangement as for transactions you process yourself in the platform. The records are yours, and you can export them whenever you need to.
- In an AUSTRAC audit, the auditor speaks to your Compliance Officer, not to easyAML. Your Compliance Officer is the point of contact for the regulator, which is why every outsourced transaction comes back to your firm for review and sign-off before it's finalised — the prepared file needs to make sense to the person who'll be answering for it.
The principle
The cleanest way to think about AML on Demand is that easyAML handles the admin and the prep; your firm makes the decisions and carries the regulatory accountability. That split is deliberate, and it doesn't change depending on whether you process a transaction yourself in the platform or send it through outsourcing. The operational work can be moved off your desk; the regulatory responsibility can't be moved off your firm.
This is true of any AML provider in the market. Outsourcing the operational work doesn't outsource the AML/CTF obligations — those sit with the entity providing the designated service, which is your firm.