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There’s no legal requirement to outsource the AFSL compliance function so it can be undertaken internally. However, it requires considerable time and adequate resourcing to be performed well. The extent of such commitment depends on the complexity of the business operated.
While compliance can be outsourced, the responsibility for it cannot. The AFSL holder remains responsible for compliance services provided by an external consultant, and so, while the AFSL holder can outsource the task, it cannot outsource responsibility and must have appropriate oversight and supervision measures in place.