Ummmmmm, yeah! So, should I have a program that attempts
to spot it and stop it? Ummmmmmm, probably!
While it makes commercial sense to have an AML/CTF (that's
anti money laundering and counter terrorism funding) program,
there's a law that makes it compulsory for certain companies to
have one, and to report to AUSTRAC. These include banks, building
societies, people in the gaming and gambling industries, gold
dealers, currency exchanges, etc.
There's even been talk about expanding the list to include
lawyers, accountants, real estate agents and certain other
businesses and professions. However, nothing is in print yet.
Too many companies wait until AUSTRAC comes knocking before
preparing or updating their AML/CTF policies and training programs.
There's recently been an increase in funding for AUSTRAC to
enable it to crack down on money laundering and in particular,
An AML/CTF program basically sets out how your organisation:
identifies risks in your business;
deals with such risks, such as undertaking pre-employment
checks and satisfying yourself that a customer is who they claim to
trains employees so they know the customers and understand
their financial activities;
monitors the effectiveness and performance of the program;
complies with very strict reporting obligations around
suspicious, large-ish and international transactions; and
keeps records about anything and everything (including your AML
Why should you care? Because you're a good corporate
citizen! And, if you're required to report or be registered,
and you aren't, AUSTRAC may take away all your cashmoneys with
a nasty fine. In April AUSTRAC dished out its biggest fine yet
– a hefty $336,600 for providing money transfer services
through unregistered remittance businesses. But it gets better -
courts can issue fines of up to $18 million, or imprisonment!
So, if you deal in precious metals and stones or handle lots of
money, get yourself an AML/CTF program and make sure your staff
understand it, if not because AUSTRAC says you have to, then
because it's a good idea to not have your name associated with
money laundering and terrorism funding.
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