• Embed AML/CTF, Privacy Act, and Corporations Act obligations into the governance framework.

• Elevate compliance risks to the Board Risk & Compliance Committee.

Environmental Scanning & Monitoring Tools

• Use AML/CTF analytics, privacy monitoring tools, self-assessments and independent reviews to detect issues early and maintain compliance.

Scenario Planning & Contingency Strategies

• Develop scenarios for AML investigations, privacy breaches, climate disclosure and cyber incidents.

• Establish rapid escalation protocols, communication and contingencies plans.

Centralised Risk Register

• Create a detailed risk register capturing likelihood, impact, controls, mitigation plans, and accountability.

• Use to monitor AML/CTF risks, privacy risks, climate disclosure risks, and external event impacts.

Climate-Related Financial Disclosure Governance

• Strengthen governance for mandatory climate reporting under the Corporations Act, NGER Act, and ASRS.

• Implement data verification controls and independent assurance to avoid misreporting.

  
  

• in addition to data analytics reports, would invest in staff to review output of reports. Would also invest in training to frontline staff to increase level of transaction monitoring. Control testing would review outputs of report and analysis compared to actual transactions. AML obligations would be linked to Risk registers (eg there is a risk of layered transactions not being detected)

Privacy Act

• Data analytics flag potential privacy breaches after the fact. And requires someone to review and detect and decide on output. As with AML, invest in training to support staff identify in addition to automatic detection. Risk register could be linked to reporting obligations to ensure mandatory disclosure within 72 hours of a breach

Climate disclosure

• The key risk that stands out to me is that the data may not be accurate of able to be validated. Robust controls and assurance from Line 2 and Line 3 to challenge reporting to give senior leadership and board comfort in accuracy of disclosures. To support corporation act compliance

Contingency Planning

• Recommend business consider changes to climate related disclosures. For example, what if government changes legislation and mandates a predefined offset amount that must be achieved by business. How would this be reported and monitored?

• AML - as is being seen today, scams accord / scams safe strategy. What other regulations could change - for example, if $10K is no longer considered the amount for A TTR and is changed to $5K - what effort would be required to achieve compliance