There are elements of your compliance framework that appear sound. However, there are likely gaps in how consistently this can be demonstrated in practice.
Your responses suggest that your position may hold in some areas, but not reliably across the business.
This is where moderate exposure typically sits.
Under ASIC scrutiny, businesses are not assessed on design alone. They are assessed on whether systems operate consistently and can be evidenced when tested.
Where this breaks down, it usually occurs in one of these areas:
- Processes are followed in most cases, but not consistently
- Reviews have been completed, but are not recent or sufficiently robust
- Documentation exists, but does not clearly support outcomes
These gaps are often not visible internally until they are tested.
In practice, this typically becomes visible during file reviews, targeted surveillance, or when issues escalate into reportable breaches.
What this means for you
Your position is not inherently weak, but it may not hold up consistently under scrutiny.
This does not reflect a lack of effort. It reflects misalignment between systems, behaviour, and evidence.
Identify your gaps
There are specific areas where your position may not hold up under review. These should be identified and strengthened.