AML/CTF Changes
- Assess whether your business and advisers are impacted by Tranche 2 changes.
- Decide whether affected services will continue.
- Complete licensee and client risk assessments before March.
- Update policies, processes, and ensure staff are trained .
Investment Governance
- Review Investment Committee procedures to confirm appropriate rigor of product due diligence, that conflicts are managed, and decisions are properly documented.
- Ensure records reflect the diligence of IC members.
Reportable Situations
- Align policies with June 2025 relief and train staff.
- Review breach assessment and documentation procedures.
- If you have no incidents or reportable situations, check whether your team needs training to identify these!
Cyber Security
- Review cyber governance against a recognised framework, such as the Australian Cyber Security Centre Essential Eight.
- Include cyber risk management as a standing agenda item in Responsible Manager meetings.
- Maintain evidence and testing: Table records in Responsible Manager meetings and Board/Partner meetings.
Disclaimer: This template has been prepared by The Principals Community Pty Ltd ABN 85 654 340 897 (PC). As a template, it is a guide only and is not a comprehensive statement on any matter and should not be relied upon as such. It does not contain, and should not be taken to contain, any financial product, legal, taxation or other advice. PC does not represent or warrant in any way that the information contained in this template meets the requirements or particular business objectives of an Australian Financial Services Licensee (Licensee) or its representatives. You should review and amend this template to suit the Licensee’s circumstances and seek legal or other professional advice as applicable. PC does not accept any responsibility for the obligations of the Licensee or its representatives. The Licensee is solely responsible for its obligations and ensuring they meet them.
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