Separate shared work from accountability
A reporting group can organise common risk management and compliance arrangements. AUSTRAC explains that the lead entity has group-wide responsibilities in addition to the obligations of individual reporting entities. Membership is therefore not a reason to stop checking what your entity must do. Start with the services each member provides and the work allocated under the group arrangements. The key question is who performs each task and how the responsible entities know that it has been performed properly.
- Member services
Identify the designated services each member provides.
- Shared arrangements
Record which tasks the group performs and how results are passed on.
- Lead entity duties
Check the lead entity responsibilities alongside each member obligation.
Distinguish shared tasks from entity duties
These are connected responsibilities, not a transfer of every obligation to the lead entity.
Connected concepts. Lines do not show ownership or a reporting hierarchy.
Create a responsibility map
A suggested group map has four columns: obligation, performing team, accountable entity and evidence location. Include customer checks, reports, policy maintenance and handling of issues. Where one team serves several members, record how it identifies the correct entity for each case. Use actual customer files to test that the map works. A central policy is difficult to apply if staff cannot tell which entity provides the service or which local procedure covers a different operating model.
Example: one shared team
Imagine two member entities use a central compliance team. The team produces common procedures, but the entities serve different customer types. A useful review asks whether the common procedure covers both and whether local differences are recorded. It also asks how each member receives information about missed checks or incomplete records. The example shows a control design issue. It does not assume that sharing staff is wrong or that identical procedures are required for every member of a reporting group.
- Shared team
A fictional central team supplies procedures to two member entities.
- Member A
Check how the procedure applies to this member’s customers and services.
- Member B
Check its different operating conditions and local issues.
- Responsibility
Shared work does not erase each entity’s applicable obligations.
Two members, one shared compliance team
Hypothetical example. The labelled links explain the arrangement; they do not determine its legal treatment.
Hypothetical example. Shared compliance team. Member A: Receives shared procedures. Member B: Receives shared procedures.
Test the handovers
Before relying on the group arrangement, test one ordinary file and one exception across the teams involved. Check that instructions, decisions and records reach the people who need them. Identify who resolves an issue that crosses entity boundaries. Revisit the map when a member joins, leaves or changes its services. Formation, enrolment and lead-entity eligibility need their own checks against current guidance. Keep those administrative decisions separate from evidence that the shared compliance work operates effectively in daily practice.
Check local exceptions
Give each member a way to report when the shared procedure does not fit its work. Record the approved local response and how the group learns from it. This avoids informal variations that remain invisible to the lead entity and makes later review of group arrangements more useful and specific.