Preserve the instruction in force
Earlier AML program versions show the instructions that applied when work was done. Approval records connect those instructions to the decision that authorised them.
Section 26P requires senior-manager approval of the risk assessment and AML/CTF policies, including updates.
Section 116 requires records reasonably necessary to demonstrate compliance with Part 1A. They remain subject to its continuing relevance and retention requirements.
Source: Federal Register of Legislation: 26P and 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
Invented example. Illustrative sequence, with no elapsed-time scale. Do not backdate missing approvals; retention duties need their own review.
Separate reference points. Position does not show elapsed time or a shared deadline.
Use a simple version register
A practical version register identifies the document, version, approval, operational start and replaced version. Describe the relevant change.
Keep approved instructions separate from working drafts. Link changes to related forms or system instructions.
Invented example: a revised review trigger
In a fictional business, a new policy changes when staff refer a customer file for review. A later reviewer examines an older file.
The earlier approved instruction shows the process that applied then. The reviewer must still examine whether that process met the applicable duties.
Keeping an old version explains the history. It does not make a defective instruction correct.
Record corrections honestly
If approval evidence is missing, investigate and record the gap. Do not backdate a new approval.
Date any later explanation and state its supporting evidence. Preserve older records while the applicable retention duties continue.
Replacing a policy does not, by itself, start the final seven-year period under section 116. The record must first cease to be relevant to compliance.
Connect versions to training
Record the operational change communicated to staff and the location of the current instruction. Identify any form that still uses the old process.
Correct the mismatch and record the result. This connects the approved change to the work staff perform.