Preparing for a CSP Compliance Review

Key Points

ACRA-appointed reviewers assess risk evaluation, internal controls, customer checks, beneficial-ownership information, suspicious-transaction reporting and staff communication and training. The review covers money laundering, proliferation financing and terrorism financing. A detailed report follows. Findings may lead to follow-up reviews, written questions, on-site inspections or staff interviews, so the exercise is broader than checking registration validity.

Prepare Evidence of How CSP Controls Operate

Treat the review as an examination of operating controls, not just a check that written policies exist. As practical preparation, organise an index linking risk assessments, customer-identity checks, enhanced due diligence, beneficial-ownership records, staff communications and training to the relevant review areas. Use actual records from the work performed; do not backdate documents or describe an unimplemented procedure as an established control.

ACRA’s eight areas include both collecting beneficial-ownership information and providing that information to ACRA. They also separately address suspicious-transaction reporting, communication of internal controls and the scope and frequency of training. For handover, identify each record’s custodian and how it demonstrates the process. An employee training attendance list, for example, should be considered alongside what the programme covered rather than treated as proof that every control is effective.

ACRA appoints private-sector reviewers, and the firm receives a detailed report. Findings may lead to further reviews, written enquiries, on-site inspections or staff interviews. Keep the report, response evidence and remedial-work status together. This preparation does not promise a favourable finding or replace the CSP’s AML, proliferation-financing and terrorism-financing obligations. Follow any actual ACRA request rather than inventing a universal response deadline or treating every finding as the same penalty.