A guided enquiry, four steps at a time. Every client file now carries a
source of funds and wealth enquiry: why you are asking, what the customer said
the money came from, whether you verified it or documented and monitored it
(with your reason), and your conclusion. One step on screen at a time, with a
bar showing where you are. Save and come back keeps a part-finished
enquiry on the file; before the first save, your answers live safely in your
browser.
It knows when AUSTRAC gives you no choice. Tick what applies (a foreign
politically exposed person, a PEP with a high-risk customer, relevance to a
customer's high ML/TF risk, virtual asset cash exchanges) and the form works
out whether the enquiry is required rather than a judgement call, tells you on
the spot, and records the basis on the file, including AUSTRAC's
must-not-provide rule where it actually applies.
Concluding is deliberate, and corrections leave a trail. Concluding "not
established, but continuing" requires the three things AUSTRAC expects:
whether you considered a suspicious matter report, why continuing is
appropriate, and the measures managing the risk. A concluded enquiry is
read-only; the only way to change it is to reopen it with a recorded reason,
and the conclusion you set aside stays on the record.
One change to sign-off: completing CDD for a high ML/TF risk client now
expects a concluded enquiry. Clients signed off before today are not affected.
It lands in your AUSTRAC audit pack as a
readable report (PDF) and a filterable spreadsheet (CSV), with an optional
source category (salary, business income, inheritance, gift and so on) so
"show me every inheritance-based enquiry" is a filter, not a read-through.
Your earlier notes stay put. Free-text source of funds notes recorded
before today remain on the client's EDD card, still yours to edit, and keep
flowing into the audit pack. Nothing was moved or rewritten.