ASIC expects Australian Financial Services Licensees and Australian Credit Licensees to maintain documented governance, systems and controls that support ongoing compliance. The infrastructure should cover regulatory obligations, risk management, representative supervision, complaints, incidents, breaches, training, monitoring, record keeping and remediation, with evidence that each component operates effectively in practice.
Expanded Answer
A licensee’s compliance infrastructure is the connected framework used to identify obligations, allocate responsibility, manage regulatory risk and demonstrate compliance. It should be appropriate to the nature, scale and complexity of the business. Policies alone are insufficient where the licensee cannot show that controls are implemented, monitored and improved.
Core documents commonly include governance frameworks, compliance policies, obligation and risk registers, representative supervision procedures, complaints and breach processes, training plans, monitoring programs and record-retention requirements. Supporting systems should assign responsibilities, record evidence, track incidents, schedule reviews, escalate overdue actions and produce meaningful management reporting. Controls should include approvals, attestations, file reviews, reconciliations, access restrictions, quality assurance and remediation verification.
Key components:
- Document each regulatory obligation, responsible owner, control and evidence requirement.
- Implement systems that record compliance activities, incidents, findings and corrective actions.
- Test whether controls operate effectively and escalate recurring or material weaknesses.
Why it matters
Weak or disconnected compliance infrastructure can allow regulatory failures to remain undetected and remediation to become inconsistent. Effective infrastructure gives responsible managers and senior management reliable evidence of compliance, supports timely intervention and helps the licensee respond to ASIC surveillance or enforcement scrutiny.
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Practical guidance
- Map each regulatory obligation to a responsible owner, documented control and retained evidence.
- Configure systems to record monitoring, incidents, complaints, breaches, actions and completion dates.
- Test controls regularly and verify that identified weaknesses are escalated and remediated.
Further reading
What regulators expect from your compliance infrastructure
The 5 tests of effective compliance infrastructure
How do you know if your compliance infrastructure actually works?