Generate a Policy – Firm Verify

Generate a Policy | Firm Verify Help

The Create Policy wizard guides you through building your firm's AML/CTF Policy document in Firm Verify. The policy covers personnel responsibilities, client obligations, and maintaining your AML/CTF program — based on AUSTRAC's starter kit.

How to start

1	Go to Firm > Program.

2	Click Generate. The Generate Documents modal opens.

3	Click Generate on the Policy card.

4	The Create Policy wizard opens. Work through each step using the left-hand sidebar, or click any step to jump directly to it.

Generate Documents modal showing Risk Assessment, Policy, Process and Program cards — Program is disabled until all prerequisites are met

Generate Program prerequisite The Program Generate button is disabled until your firm has current approved documents for all three components: Risk Assessment, Policy, and Process.

Wizard sections and steps

The Create Policy wizard has three sections. Each section contains multiple policy steps.

Create Policy wizard — Personnel section, Align personnel to roles step showing expandable policy items with Details field

Section	Steps
Personnel	Align personnel to roles Conduct personnel due diligence Deliver personnel training
Clients	Initial CDD Ongoing CDD Pre-commencement customers Escalation and enhanced CDD Report to AUSTRAC Tipping off Offboarding
Maintain AML/CTF Program	Maintain the program Conduct periodic effectiveness checks Independent evaluations Record keeping Reporting obligations

Create Policy wizard — Clients section, Report to AUSTRAC step showing responsibility items

Editing policy content

Each step contains a list of pre-filled policy items based on AUSTRAC's starter kit. Expand any item to reveal its Details text field — editable free text that describes how your firm implements that policy obligation.

Edit any item's Details text to reflect your firm's specific approach.
Add new items using the Add policy + button at the bottom of each step.
Delete items using the bin icon. A confirmation is shown before removal.
Restore deleted defaults by using the Add policy + button and selecting from the restore list.

Completing the policy

Once all steps have been visited and there are no outstanding errors, the Generate Policy button is enabled on the Finish step. An attention bar lists any incomplete steps.

Click Generate Policy. Firm Verify generates your policy document and immediately asks whether you want to send it for review.

Select Send for Review to assign a reviewer — status moves to Under Review.
Select Cancel to return to the Program screen — document is saved as Draft.

Document statuses

Status	When it applies	Available actions
In Progress	Saved using Save for later, before generating.	Edit, Delete
Draft	Generated but not yet sent for review.	Edit, Delete, Send for Review
Under Review	Sent to a reviewer, awaiting decision.	Reviewer: Review. Others: View, Cancel Review
Approved	Reviewer has approved. Next review date auto-set to 3 years from today.	View
Rejected	Reviewer has rejected with a comment.	Edit, Delete

Saving and cancelling

Button	Behaviour
Save for later	Saves progress without full validation. Title and Version are required. Status set to In Progress.
Generate Policy	Available on the Finish step only, when all steps have been visited and are complete. Generates the document and prompts Send for Review.
Cancel	If changes exist, shows a Discard confirmation. Choose Discard to exit without saving, or Go Back to continue editing.