How can a culture of compliance be achieved?

AUSTRAC recognises that reporting entities have numerous regulatory obligations and expects that AML/CTF requirements will become part of a business's broader compliance programs and culture.

The values, attitudes and beliefs exhibited by management represent the single greatest influence on the successful implementation of a culture of compliance. If the board and management are not seen to be committed to compliance, it may send the message that compliance is discretionary.

Several factors that organisations need to consider to successfully integrate compliance into their culture are also required elements of AML/CTF programs; for example, an ML/TF risk awareness training program and oversight of AML/CTF programs by boards and senior management. However, to ensure that implementation of the AML/CTF program is successful, the following elements of a culture of compliance should be considered in conjunction with the required elements of AML/CTF programs.

Compliance framework

Compliance policies, processes, resources, training, monitoring and reporting are the foundation of a culture of compliance.

Behavioural factors

For the compliance framework to be effective it needs to be embedded in the culture, which will require training and demonstration and encouragement of the appropriate behaviours by management.

Structural issues

Compliance should be integrated into all operational areas of the business rather than a separate compliance function.

Business planning

A formal business plan will assist management throughout the organisation to incorporate compliance activities into units.

Inter-business unit management

Some compliance functions will extend across several business units which will require careful planning and management.

Resourcing

Senior management allowing adequate time and resources for compliance activities.

Compliance culture: concerns and usage scoresheet (pdf 46kb)