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From 1 June 2014, new AML/CTF Rules require ‘reporting entities’ to implement enhanced customer identification procedures.

Here’s a quick summary of the new requirements and what you need to do about them.

What's New?

New AML/CTF Requirements

What to do?

The good news is that AUSTRAC won’t be enforcing these requirements until 1 January 2016, provided you take some action now. Here’s what you need to do:

  • As soon as possible - Identify your high risk customers and carry out the new identification, verification and due diligence procedures; and
  • Before 1 November 2014 - Develop a transition plan outlining when and how you will review your ML/TF risks and AML/CTF Program in order to be fully compliant by 1 January 2016.

Make sure you document your plan and get it approved by your Board. After that, monitor progress against it on a regular basis as AUSTRAC might ask you for information about how you are getting on!

Remember – if you’re a financial planner you’re only a ‘reporting entity’ if you hold an AFSL, although you will need to meet the new customer identification requirements on behalf of your licensee.

The AML/CTF Rules are complicated - so when in doubt, seek legal advice. We’re always happy to help.

Author: Lesley Hambusch

July 2014

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