The International Organization for Standardization has now
published the international standard for compliance management
systems ISO 19600-2014.
ISO 19600 is based on and will replace AS 3806-2006, the
Australian Standard for compliance programs – as a result,
when regulators adopt ISO 19600 as their compliance benchmark for
regulated entities, Australian companies who already have an AS
3806-aligned compliance system will find they have a competitive
advantage when they compete internationally.
What do you need to do now?
The principles in ISO 19600 are substantially similar to those
in AS 3806, so any organisation whose compliance system already
aligns with AS 3806 will have little to do apart from a quick
For those organisations with compliance systems that needed some
work to make them align with AS 3806, this is a further reason to
Australian organisations which have adopted AS 3806 should take
note of the following requirements of ISO 19600:
consider compliance obligations which are mandatory (eg.
legislation, licences and permits) and voluntary (eg. internal
codes of conduct, industry codes);
ensure your compliance management system is planned and
developed within the context of your organisation's commercial
environment, objectives, strategic direction and organisational
the express list of the kinds of documentation which must be
present to support the compliance management system;
adopt a risk-based approach to compliance and in particular,
develop an organisational risk appetite for legal compliance
integrate your compliance management system with your business
align your operational targets with compliance
ensure your organisational culture and the actions taken by
your leaders promote a compliance culture; and
engage with external and internal stakeholders to determine
their compliance expectations of your organisation.
These features are arguably implicit in AS 3806, but have been
given greater, stand-alone emphasis in ISO 19600.
Clayton Utz communications are intended to provide
commentary and general information. They should not be relied upon
as legal advice. Formal legal advice should be sought in particular
transactions or on matters of interest arising from this bulletin.
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