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Austrac Alert
- By Alan Fotheringham
- Published 27/02/2009
- Risk Watch
- Unrated
On 31 March fund managers are required to lodge their Anti-Money Laundering/Counter-Terrorism Financing (AML/CTF) Compliance Reports for the year ended 31 December 2008 to AUSTRAC.
What AUSTRAC expects?
In that report, AUSTRAC will be expecting you to advise that your AML/CTF program was in operation last year and that you have taken at least some tangible steps towards meeting the ongoing customer due diligence and special reporting obligations which commenced on 12 December 2008.
Independent review
The legislation calls for you to arrange for an 'independent review' of your AML/CTF program. We encourage you to see this review as an opportunity to obtain expert third party comfort that your AML/CTF policies and procedures are being consistently applied on a day-to-day basis in areas such as:
• AML/CTF risk assessment (including risks associated with operations in other jurisdictions)
• KYC policies and procedures (including record keeping arrangements etc.)
• Employee due diligence
• Ongoing customer due diligence
• Suspicious matter reporting
Although the legislation does not clearly define 'independent', it is reasonable to assume that AUSTRAC will have greater confidence in organisations which interpret this strictly to refer to third parties other than those who assisted in designing the program.
Moore Stephens’ Risk Management Division has considerable expertise in the preventive and detective techniques necessary to assist you mitigate the risk of fraud generally as well as to minimise the risk of non-compliance with AML/CTF legislation. The resources of this division are available to you if you are interested in an AML/CTF 'Health Check' now that the 15 month 'non-prosecution period' for part A of the program has expired.
If you and/or your designated AML/CTF compliance officer have any queries about the day to day operation of Parts A or B of your AML/CTF program, please contact Alan Fotheringham, Associate Director, on telephone (03) 8635 1865.
What AUSTRAC expects?
In that report, AUSTRAC will be expecting you to advise that your AML/CTF program was in operation last year and that you have taken at least some tangible steps towards meeting the ongoing customer due diligence and special reporting obligations which commenced on 12 December 2008.
Independent review
The legislation calls for you to arrange for an 'independent review' of your AML/CTF program. We encourage you to see this review as an opportunity to obtain expert third party comfort that your AML/CTF policies and procedures are being consistently applied on a day-to-day basis in areas such as:
• AML/CTF risk assessment (including risks associated with operations in other jurisdictions)
• KYC policies and procedures (including record keeping arrangements etc.)
• Employee due diligence
• Ongoing customer due diligence
• Suspicious matter reporting
Although the legislation does not clearly define 'independent', it is reasonable to assume that AUSTRAC will have greater confidence in organisations which interpret this strictly to refer to third parties other than those who assisted in designing the program.
Moore Stephens’ Risk Management Division has considerable expertise in the preventive and detective techniques necessary to assist you mitigate the risk of fraud generally as well as to minimise the risk of non-compliance with AML/CTF legislation. The resources of this division are available to you if you are interested in an AML/CTF 'Health Check' now that the 15 month 'non-prosecution period' for part A of the program has expired.
If you and/or your designated AML/CTF compliance officer have any queries about the day to day operation of Parts A or B of your AML/CTF program, please contact Alan Fotheringham, Associate Director, on telephone (03) 8635 1865.
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