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immunity

AUSTRAC v Tabcorp: What can we learn to date?

In the recent judgment of Justice Nye Perram in the interlocutory matter AUSTRAC v Tabcorp (TAB Limited), the judge made comments which should make boards, senior management, risk and compliance teams, and AML professionals sit up and take note. The comments of most significance related to anti-money laundering (AML) compliance programs, money laundering and terrorist financing (ML/TF) risk assessments, and AML program governance. The judge’s comments also have relevance to record creation and record keeping obligations.

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Stay on the straight and narrow. A reminder that your reports are due.

It is that time of year again for completing your AUSTRAC compliance report. Yes, it is a rather easy document to complete. And yes, you might consider it an irritant. However, be warned as completing the S47 Report should be taken seriously. Questions should be answered truthfully and accurately, even if that means confessing to AUSTRAC that your organisation has not fully implemented an AML Act or AML Rule obligation.

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