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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?

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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