Record the reason for the answer
An outside-scope conclusion is more useful when another person can understand how you reached it. AUSTRAC explains that regulation depends on designated services and directs businesses to seek independent advice if they are unsure. A decision note can preserve the facts and reasoning behind that assessment. It can connect the actual work with the service criteria and identify the material used. This page does not say that every outside-scope business has a legal duty to create such a note.
- Facts
Describe the service, customer and provider. Separate assumptions.
- Relevant provision
Identify the service item, conditions and evidence considered.
- Reason and limit
Record the conclusion and any work excluded from the engagement.
- Change in work
Recheck the conclusion when instructions or material facts change.
Make a scope decision traceable
Suggested record structure. This does not assert a record-making duty for every business assessed as outside scope.
Follow the process from top to bottom.
Use a focused decision note
A suggested note starts with the service as performed, the customer and the entity providing it. Add the statutory item considered, the relevant condition and the evidence for your conclusion. Separate confirmed facts from assumptions. If the decision depends on not performing a particular step, write that limit explicitly. Record the date and the person who made the decision. Attach only the material needed to understand it, so the note remains usable when staff revisit the same question.
Example: a limited engagement
Imagine a firm accepts an engagement with a carefully limited output. The scope reviewer considers the current guidance and concludes that the agreed work is outside the designated service being assessed. The useful record identifies the limit and the reasoning. If the customer later asks the firm to do more, staff can compare the new instruction with that boundary. The earlier conclusion is not automatically wrong, but it may no longer describe the work now proposed. That change should trigger another review.
Keep uncertainty visible
Do not convert an unresolved question into a confident no merely to complete an intake form. Give the question an owner, identify the missing fact and state what further guidance or advice is needed. Keep the final decision with the engagement or service map. Review it when services or authoritative guidance change. A documented conclusion helps explain your position, but it does not make an incorrect interpretation correct. Use qualified advice where the facts or legal boundary need more than the available guidance provides.
Review dependencies explicitly
If the conclusion depends on a fact supplied by another team, identify that fact and its owner. For example, the work may be limited by an engagement instruction. Ask how the limit is enforced in practice. A future reviewer can then test the dependency instead of repeating the entire assessment without context.