Preserve the instruction in force
A current policy explains what staff should do now. It may not explain what applied when an earlier file was handled. AUSTRAC identifies document version and approval details as useful records. The Act also requires program-related evidence to be retained under its specific framework. Keep the connection between the approved instruction and the period in which it was used. Replacing a document should not automatically erase the evidence needed to understand decisions made under the previous version.
- Senior manager: Record keeping
- Anti-Money Laundering and Counter-Terrorism Financing Act 2006: Section 116
- Earlier version
Preserve the approved instruction used for the earlier file.
- Change and approval
Record the new version, approval evidence and operational start.
- Later review
Use the version register to identify what applied when the file was handled.
Keep the instruction that applied at the time
Illustrative sequence, with no elapsed-time scale. Do not backdate missing approvals; retention duties need their own check.
Separate reference points. Position does not show elapsed time or a shared deadline.
Use a simple version register
A suggested register identifies the document, version, approval, operational start and the version it replaces. Include a short description of the material change. Keep the approved file separate from working drafts so staff do not accidentally use an unfinished revision. Where a policy change affects a form or system prompt, record that connection. This lets the business check whether the supporting tools changed with the policy rather than assuming that publication of a new document updated the whole process.
Example: a revised review trigger
Imagine a business changes the circumstances that send a file for internal review. Months later, a reviewer examines a file completed before the change. Access to the earlier instruction helps explain which process staff were expected to follow then. The reviewer can still assess whether that process met the applicable requirements. Preserving the old version is not a defence for a defective rule. It is evidence of the actual instruction and makes the historical assessment more accurate.
Record corrections honestly
If an approval record is missing, investigate what evidence exists and document the gap. Do not backdate a new approval or edit an old message to imply that it covered later text. Any retrospective explanation should identify when it was made and what evidence supports it. Keep superseded records under the applicable retention rules, including their continuing relevance. Use the version register during staff training and independent evaluation so that document history, implementation and review all refer to the same identifiable set of instructions.
Connect versions to training
Record which operational change staff were told about and where the current instruction is available. If the policy changed but the form did not, identify the mismatch and repair it. This connects document control to actual behaviour and gives later reviewers a clearer basis for checking the implementation of an approved change.