The lead entity of a reporting group must have AML/CTF policies that ensure appropriate sharing of information between members for CDD and for managing each member's ML, TF and proliferation financing risks; ensure sharing needed for members to comply with the Act and the lead entity's policies; where one member discharges another's obligation, state which members may discharge which obligations and ensure each reporting entity makes or can access records showing the discharge; and ensure confidentiality and appropriate use of shared information, including to prevent tipping off. Rules 5-16 adds keeping up-to-date records of group membership and its changes. Group members that are not the lead entity must also comply with the lead entity's policies that apply to them (s 26G(2)), and a member's civil penalty contravention is also the lead entity's (s 236B(6)).
The graph holds this control, the 0 it maps to, and the evidence behind each claim, over MCP and REST.