Part A — your risk-based framework
Part A is where the agency principal sets the risk appetite, governance, and oversight. It is not a generic template — it has to reflect your customer mix, your channels, your services, and your geography.
A Part A program must cover the following at minimum:
- Risk assessment — customer types, channels, services, geographies — refreshed at least annually.
- Governance — who in the agency owns the program, how the principal approves it, how board-equivalent oversight works.
- Compliance officer designation — name, role, escalation path.
- Independent review schedule — how often, by whom, what the report covers.
- Employee due diligence — pre-employment screening, ongoing monitoring of staff with sensitive access.
- Training program — content, frequency, role-specific tracks, completion records.
- Ongoing customer due diligence — triggers for re-verification or enhanced due diligence.
- Reporting framework — who lodges TTRs and SMRs, how internal escalation works inside the tipping-off boundary.
Part B — customer due diligence procedures
Part B sets out the practical steps your staff follow at customer onboarding and during the deal.
- Customer identification — what documents you collect for individuals, companies, trusts, foreign entities.
- Verification — the standard you verify each document to (sighting original, certified copy, electronic verification).
- Beneficial ownership — for companies and trusts, who you identify as the natural-person beneficial owners.
- Sanctions and PEP screening — when you screen, against which lists, how often you re-screen.
- Enhanced due diligence — the triggers (foreign PEP, high-risk jurisdiction, cash-heavy buyer, unusual structuring) and the additional steps.
- Decision documentation — what gets recorded for each customer, where it lives, who has access.
How AustracCheck generates the draft
Your principal completes an onboarding questionnaire covering services offered, customer mix, channels, geographies, and risk appetite. The platform generates a tailored draft for both parts that the principal can review, edit, and adopt. The draft is not legal advice — your agency owns adoption, customisation, and ongoing review.
Once adopted, the program is operational not paperwork
AustracCheck wires each Part A control and Part B procedure to a workflow inside the platform. When a sales agent onboards a customer, the right Part B step fires. When the year ticks over, the Part A risk-assessment refresh is queued. The program stops being a PDF that sits on a shared drive.