Governing body, senior manager, compliance officer: one person three hats

People search “sole trader AML governance” when a sole practitioner thinks three titles mean three people and is about to leave the governance page blank. Checked against AUSTRAC’s governance guidance for sole traders on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. Whether a sole trader can be their own officer is the sole trader compliance officer page. The role itself is the AUSTRAC compliance officer. The sector map is /tranche-2.

Three lines, one person

AUSTRAC’s sole-trader guidance exists because the smallest business still has governance, and the governing body approves the program. The senior manager is accountable for it, and the compliance officer oversees it and can stop a designated service when customer due diligence is not done. A sole trader may be all three, and sole trader AML governance is the record of that fact, not a request to hire two more people. This page does not reproduce the guidance.

The failure mode is a single line that says owner. A later reader cannot see which decision was approval and which was oversight. Write the hats separately, with the date each started, and name who covers leave. If nobody covers leave, say so, and do not provide a designated service in a week when the only person who can pause one is away without a cover.

• Governing body. The sole trader acknowledges they are the whole body and approves the program. That approval is a dated line.
• Senior manager. The same person is accountable for the program being followed. Do not merge this into the officer line.
• Compliance officer. Authority to pause a designated service sits on this line. A title without that authority is only a title.
• Leave. Name the cover, or record that the business will not provide the service while the sole trader is away.

What each hat is allowed to be

How the program is written around those hats is the AML/CTF program for Tranche 2. This page stays with the three titles.

Where the three-hats page stops

This page is the sole trader wearing three hats on purpose. It is not the micro-business that has staff, and it is not the appointment form. FreeAML does not appoint the officer or approve the program.

What the client pays

On FreeAML the firm suite is A$0. The firm emails the client a link. Verification is client-pays. On the public list a personal KYC check is A$20 and a company or trust KYB check is A$40. Use KYB when the customer is a company or a trust. Writing the three lines is not a check, and a customer verification the program later requires is still client-pays. Confirm the live amounts on FreeAML pricing. FreeAML does not appoint your officer or approve the three hats.

Frequently Asked Questions