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Does the platform update the AML Program automatically if business services change?

Yes, the Program regenerates when business services change in Account Settings, a fresh Risk Assessment is completed, or AUSTRAC guidance updates flow through.

Yes. The Program is regenerated whenever:

  • Changes to business services are made in Account Settings (e.g. adding a new sector, ticking on additional designated services, modifying the firm's service mix).
  • A fresh Risk Assessment is completed - the new RA drives a new Program version that reflects the updated inputs.
  • Regulatory updates are pushed by easyAML - AUSTRAC guidance changes flow through to Program content automatically (see Section 21's question on AUSTRAC guidance notifications).

What runs continuously in the background:

  • Continuous monitoring detects activity trending higher than the declared risk profile and alerts the CO. For example, if the firm's actual customer mix shifts toward higher-risk segments than the Risk Assessment modelled, the CO sees an alert recommending an RA refresh.
  • Quarterly reviews are automated via effectiveness checks - the platform assesses whether the Program is operating as intended, looking at metrics like CDD completion rates, SMR/TTR lodgement timing, training currency, and overdue re-screening. The CO receives a quarterly digest summarising any items needing attention.

This automated regeneration matters because AUSTRAC's framework expects the AML Program to be current - a stale Program from 18 months ago that doesn't reflect today's business is a compliance weakness. The platform's auto-update removes the manual effort of keeping the Program current; the CO's role becomes one of approving updates rather than drafting them from scratch.

Version history is preserved - previous Program versions remain in the audit trail, showing which Program was in effect when. This is essential for evidencing compliance position at any historical point.

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