Anti Money Laundering

The Problem

Money laundering and terrorism financing are a significant and growing risk to many financial organisations. Money launders will go to great lengths to ensure that their transactions are indistinguishable from legitimate transactions.

The new AML/CTF regime under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 introduces a risk based approach to counter the AML/CTF problem. The obligations under the AML/CTF Act 2006 are imposed on a wide range of financial services organisations (reporting entities) including: banks; building societies; credit unions; superannuation funds ; and on the gambling sector.

The Risk

Every organisation covered by the regime must take a risk based approach to designing a program for identifying the degree of money laundering risks associated with their customers/clients and transactions. The program will allow the organisation to focus on those customers/clients and transactions which potentially pose the greatest risk. The program must "identify, mitigate and manage" the AML/CTF risks that an organisation may reasonably face when providing a designated service.
The key areas of an AML/CTF program are:
  • Customer Due Diligence
  • Record Keeping
  • Reporting of Suspicious Matters
  • Training of staff
  • Audit of the program
  • Appointment of an AML/CTF Compliance Officer

Our AML/CTF Services

SSAMM has real and extensive legal and consulting experience in AML/CTF in Australia, the UK, Ireland and the Philippines. With our skills in AML/CTF, risk identification and compliance framework design we can offer clients confidence that their AML/CTF needs are not only met but are effective and efficient. We understand the importance of a risk based approach as it prioritises the organisation’s effort and tailors that effort to the AML/CTF risks as every organisation is different.

Risk Identification Workshops

The key to the risk based approach is to understand the money laundering risks associated with customers and transactions. Once those risks have been identified the AML/CTF program can be designed or amended as appropriate.

SSAMM will facilitate workshops which will identify the key money laundering risk criteria: country risk; customer risk; service risk and apply them to the organisation or business unit. Situations which need enhanced controls will be identified and those controls designed. SSAMM will also deliver training programs.

AML/CTF Audits

Every AML/CTF program should be reviewed periodically, and at least annually, to ensure that it is working effectively and that it is focussing on the current money laundering risks. Remember that money launders will target organisations with real or perceived weaknesses in their AML/CTF programs. Organisations will also be required to report to AUSTRAC on its compliance with the legislation.

SSAMM will undertake an audit of your AML/CTF program to test for weaknesses and currency.

AML/CTF Training

The training and education of all relevant staff is critical to the success of a risk based approach to AML/CTF. Training must raise awareness in staff of the legal and regulatory environment in which the organisation operates, the need for AML/CTF controls, the risks to the organisation, and how its own AML/CTF program operates.

AML/CTF Implementation Program

As the AML/CTF legislation is to be implemented in phases to allow organisations to develop the necessary skills and process and procedures each organisation will need to meet these target dates. The key target dates are:

Date Target
June 2007Compliance Reports; Correspondent Banking.
December 2007AML/CTF Program; Identification and record keeping procedures.
December 2008Suspicious Matter Reporting; On-going Customer Due Diligence


SSAMM will work with your organisation to provide detailed planning and realistic timelines for achieving compliance with the obligations.

Contact Paddy Oliver poliver@ssamm.com.au or Ulysses Chioatto uchioatto@ssamm.com.au to discuss your needs.

 

 
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