Assess and document whether a person is suitable for an AML/CTF related role, such as Governing Body member, Senior Manager or Compliance Officer. The wizard guides you through six steps and produces a Suitable or Not suitable record once complete.
| Step | Name | What you do |
|---|---|---|
| 1 | Personnel Information | Confirm the person's details and record why the assessment is being done. |
| 2 | Membership | Record any CPA Australia, CA ANZ or IPA membership. |
| 3 | Verify | Add identification and background checks, with evidence. |
| 4 | Eligibility | Confirm the person's roles and answer the eligibility questions for each. |
| 5 | Suitability | Rate integrity, conflicts of interest, competence and adverse findings. |
| 6 | Decision | Record the overall outcome, rationale and next review date. |
Before you begin
Permissions
You need the Add/Edit Personnel Due Diligence authority to start, edit, complete or delete an assessment and to upload evidence. The Personnel Due Diligence authority lets you open in-progress and completed assessments read-only and download their documents.
Only one assessment can be in progress for a person at a time. If a record is already In Progress, selecting Start PDD shows a warning with a button that takes you to that record.
How to start a PDD
1 |
Open Firm. From the Main Toolbar, click Firm. |
2 |
Go to Personnel. Select the Personnel tab. |
3 |
Open the person's PDD tab. Select the person, then select the Personnel Due Diligence tab. |
4 |
Start the wizard. Select Start PDD. |
Completing the wizard
Step 1: Personnel Information
Check the Legal name, Date of birth, Residential address and Role. These are pulled from the person's record and can't be edited here.
Select a Purpose of PDD:
- New personnel in an AML/CTF related role
- Internal promotion or transfer to an AML/CTF related role
- Change in circumstances affecting suitability
- Concern about a person's conduct, suitability or competence in the role
- Triggered review
Add any Notes if needed. Purpose of PDD is required before you can save or complete the assessment.
Step 2: Membership
Select Yes, No or Unsure for Is the person a member? This covers CPA Australia, Chartered Accountants Australia & New Zealand and the Institute of Public Accountants.
If you select Yes, choose the Association (defaults to CPA Australia), enter the Membership number, and confirm Verified by and Date verified. These are pre-filled with your name and today's date.
If you select No or Unsure, you must add at least one check on the Verify step.
Step 3: Verify
Add the checks you need to be reasonably satisfied of the person's integrity, identity, competence and independence. Select Add check, choose a check type, complete its fields, then select Save.
| Check type | What to enter | Evidence |
|---|---|---|
|
Adverse media search Bankruptcy register search Employment reference check Referee statement |
Verified by and Date verified. | Files and/or notes. At least one is required. |
| National criminal history check | Verified by and Date verified. Results must be from the last 6 months. | Files and/or notes. At least one is required. |
| Statutory declaration | A signed statutory declaration. Verified by and Date verified. Notes are optional. | Files required. Notes alone aren't enough. |
| Written commitment letter | A signed statement. Verified by and Date verified. Notes are optional. | Files required. Notes alone aren't enough. |
| Driver's Licence | Issue Country, Licence Number and Expiry Date. For Australian licences, also the Licence Issue Location (state) and Card Number; both numbers are validated against the selected state. Name, Date of Birth and Residential Address are pre-filled and editable. | Optional. |
| Passport | Issue Country, Passport Number and Expiry Date. Issue Date and Passport Gender are optional. Name and Date of Birth are pre-filled and editable. | Optional. |
| Australian Medicare | Medicare Number, Individual Reference Number (1–9), Card Colour (Green, Blue or Yellow) and Expiry Date. Name is pre-filled and editable. | Optional. |
| Other | A Description of the check and, if relevant, a Unique Identifier. Verified by and Date verified. | Files and/or notes. At least one is required. |
Every check also needs Verified by and Date verified, pre-filled with your name and today's date. Date verified can't be a future date. Evidence files can be PDF, DOC/DOCX, JPEG/JPG or PNG, and you can attach more than one.
Licence, card, passport, Medicare and unique identifier numbers are masked. Select the View button to unmask them.
If a name, date of birth or address on an ID check doesn't match Personnel Information, a warning shows both values side by side. You can still save the check.
Each check type can be added once, except Other, which can be added as many times as you need. Saved checks are listed most recent first, with the check type, verifier and verification date (plus the description for Other checks). You can edit or delete a check; deleting asks you to confirm.
Step 4: Eligibility
Select at least one role the person holds or is about to take on: Governing Body, Senior Manager, Compliance Officer or Other Personnel. Roles recorded in Personnel Information are pre-selected. Answer the questions for each role selected:
| Role | Eligibility question |
|---|---|
| Governing Body | Does this person have primary responsibility for governance and executive level decisions? |
| Senior Manager | Can this person make or influence decisions affecting the whole or a substantial part of the practice? |
| Compliance Officer | Is this person an Australian resident with a degree of permanence? Does this person hold a management level position? Does this person have sufficient authority, independence and access to the resources and information needed? |
Add Notes if needed.
Step 5: Suitability
Review the documents and checks gathered so far, and record Suitable or Not suitable for each area:
| Area | What to consider |
|---|---|
| Integrity | Is the person honest and of good character, with no concerns about their conduct? |
| Conflicts of interest | Are they free of conflicts that could compromise their AML/CTF responsibilities, or can any conflicts be managed? |
| Competence | Do they have the skills, experience and knowledge to perform the role effectively? |
| Adverse findings | Did any checks return adverse results, such as criminal history, bankruptcy or adverse media, that affect suitability? |
If any area is Not suitable but you still consider the person suitable overall, explain your rationale in Notes.
Step 6: Decision
- Select the overall Decision: Suitable or Not suitable.
- Enter the Rationale for the decision.
- Confirm Assessed by and Date of assessment. Both are pre-filled and editable.
- Set a Next review date if applicable. It's pre-filled from the review date on the Personnel Due Diligence tab and must be a future date.
Saving and completing
| Button | What it does | Available on |
|---|---|---|
| Cancel closes the wizard and discards unsaved changes, after you confirm on the Unsaved Changes warning. If you were editing a saved assessment, it goes back to its last saved state. | All steps | |
|
|
Previous and Next move between steps. You can also select any step in the progress bar to jump to it. | Previous: all except Personnel Information Next: all except Decision |
| Save for Later saves your progress with a status of In Progress. Only Purpose of PDD is required; if it's missing, you're taken to it. Other validations are skipped. | All steps | |
| Complete PDD finalises the assessment as Suitable or Not suitable, based on the Decision step. If anything is still invalid, you're taken to the first error. Once everything passes, confirm the prompt to save. | Decision step only |
Step indicators
Steps you haven't opened are grey. An opened step turns green when it has no errors, or red when it still has validation errors. Errors show as soon as you enter invalid or missing information, not only when you save.
Frequently asked questions
Can I come back to an assessment later?
Yes. Select Save for Later at any step. The assessment shows as In Progress on the Personnel Due Diligence tab. Select Edit on it to continue.
Can I change a completed assessment?
Yes, with the Add/Edit Personnel Due Diligence authority. Select Edit on the record to open it in the wizard as Edit PDD. Every field can be changed, including the Decision, Date of assessment and Next review date, and you can add or remove checks and files. Select Save to keep your changes. Users with view-only access see View instead, which opens the record read-only.
Can I delete an assessment?
Yes, with the Add/Edit Personnel Due Diligence authority. Select Delete on the record and confirm. Deleted assessments can't be restored, and they no longer count towards the person's PDD status or next review date.
Do I need to re-enter details when reassessing someone?
No. A new PDD carries forward the Membership, Verify and Eligibility details from the person's most recent completed assessment. You can still edit them, for example to update a lapsed membership or add new checks.
We completed a PDD outside Firm Verify. Do we need to redo it in the wizard?
No. Select Upload PDD on the Personnel Due Diligence tab to record it instead. See Personnel Due Diligence Tab.