What happens when the CO goes on extended leave?
A 2IC (deputy Compliance Officer) is added via Account Settings > Users, completes the CO training modules, and activates with full platform access except adding or removing the primary CO.
Overview
Every Tranche 2 reporting entity must have a Compliance Officer in place at all times - AUSTRAC's framework doesn't allow ongoing gaps in CO coverage. easyAML supports this with 2IC (deputy Compliance Officer) arrangements that activate when the primary CO is unavailable.
How to set up a 2IC
Go to Account Settings → Users → + Invite User and select the role "Compliance Officer 2IC". The 2IC accepts the invitation, sets up their password and MFA, and completes the CO training modules (about 1.5-2 hours). Once trained, the 2IC has full platform access except the ability to add or remove the primary CO. They can sign off Risk Assessments, lodge SMRs and TTRs, manage CDD escalations, and represent the firm to AUSTRAC. Multiple 2ICs are supported - useful for larger firms where deputy coverage rotates or several senior people share the role.
When a 2IC is used
- Planned leave - annual, parental or sabbatical. Hand over the day before leave starts.
- Unplanned absence - illness or family emergency. Because the 2IC is already trained and credentialled, coverage is immediate.
- CO transition - when the primary CO is leaving permanently, promote the 2IC to primary CO.
You can also arrange cross-firm 2IC backup, where two businesses cover each other's deputy roles during leave. See AUSTRAC's AML/CTF Program reform materials for CO appointment expectations.
Related articles
- easyAML (Platform) Set-up Checklist
- How do I appoint my compliance officer?
- What does the Compliance Officer role actually require?
- If our AML/CTF compliance officer is away for a period — for example, sick leave or annual leave — do we need to appoint someone else as the compliance officer? How does this work for a micro-business
- What user roles does easyAML support?