Combine roles carefully
A sole trader may perform several governance functions personally. AUSTRAC recognises combined roles but retains their underlying duties. An individual who is both governing body and compliance officer does not need to provide regular compliance officer updates to themselves as governing body. This is an internal governance exception. It does not remove duties to submit reports to AUSTRAC. Do not extend it to every small company. Record how the person will handle oversight, decisions and daily coordination.
Set aside time to review your procedures
A practical approach is to separate ordinary customer work from scheduled checks of whether the procedures work. You can do both as one person while recording them differently. Keep a short issue list, review repeated problems and record decisions to change the process. When approving an update, identify the document version and the capacity in which you act. This avoids unnecessary ceremony while keeping evidence that the different governance functions were considered. The form can stay simple if it supports clear decisions.
- Customer work
Apply the procedure to an individual file.
- Review
Check whether the procedure works across files.
- Approval
Record the version and the capacity in which you approve it.
One person can perform different functions
Read this visual with the source conditions and explanation in this section.
Separate evidence questions. An answer to one does not settle the others.
Example: a recurring exception
Imagine a sole trader repeatedly encounters the same missing-information problem. Completing each file one at a time may resolve the immediate cases but leave the procedure unclear. A separate review note can identify the pattern, decide whether the instructions need changing and set a follow-up check. The same person may perform those steps. This is an operational example, not a prescribed meeting format. Its value is showing the difference between processing a customer and improving the control used for future customers.
Keep independence separate
Combining internal roles does not mean every assurance activity can be performed by the same person. Check the independent-evaluation requirements separately, including the evaluator’s relationship to the work assessed. Make practical arrangements for absence, access to records and unresolved questions. If you incorporate, add staff or change services, revisit the earlier role analysis. A structure that was appropriate for an individual business may need adjustment after growth. Small-business governance should be proportionate, but it should still show who does the work and how weaknesses are addressed.
Make time for oversight
Put a practical review point in your working routine and keep the output brief. Look for repeated exceptions, unresolved questions and changes in services. Record a decision or an explicit need for further information. Keep the review record separate from the customer file so you can find the decision later.