Insights from our AML Experts

AML/CTF Amendment Act 2024 -Exposure Rules – Initial CDD – Legal or official documentation “Modernisation & Simplification” (cough). Draft Rule 27 – Additional matters for initial customer due diligence – will require a reporting entity “to establish on reasonable grounds the following”: “For any customer other than an individual acting on their own behalf or […]

AML/CTF Amendment Act 2024 – Proliferation Financing & The Exception A quick look at Section 26F(11) – An Exception, or is it? Section 26F(11) states: Exception 26F (11) Despite subsection (1) (AML/CTF Policies), a reporting entity is not required to develop or maintain policies, procedures, systems and controls that specifically deal with the risk of […]

AML/CTF Amendment Act 2024 “Modernisation & Simplification” (cough). The AGD has published the government response to the Senate Legal and Constitutional Affairs Legislation Committee report on the AML/CTF Amendment Bill 2024 Yes, a response to a bill that is already in force. Leaving that aside, the response makes interesting reading. It’s mostly self-serving, as you’d […]

AML/CTF Amendment Act 2024 – No Statutory Review “Modernisation & Simplification” (cough). Due to the lack of an exposure draft of the AML/CTF Amendment Bill, 2024, which would have allowed proper scrutiny, the proverbial dogs in the street know that the AML/CTF Amendment Act 2024 has many flaws. Nothwithstanding what the Government says, the Act […]

AML/CTF Amendment Act 2024 – Proliferation Financing What do you think it means? If you were assessing your organisation’s reasonable proliferation financing risk, how would you define proliferation financing? Be warned! The definition of proliferation financing contained in the Australian AML/CTF Amendment Bill is a whole lot broader than what you might think. It is […]

AML/CTF Amendment Act 2024 – Consultation on Draft Rules More “modernisation & simplification” (cough). Scalability of Outcomes – The consultation paper at page 8 states: “The outcomes-based approach to the new General Rules, which avoids prescribing processes reporting entities must carry out, also supports the rules to be flexible and scalable to the diverse regulated […]

AML/CTF Amendment Act. 2024 – Infringement Notices More “modernisation & simplification” (cough). Does the punishment fit the crime? From 31st March, 2026 the new list of desingated infringement notices will be effective. The list at section 184 is long and can / will trip up even the most fastidious reporting entity or compliance team (aren’t […]

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EBINAR: Do you want to know more about the new KYC / CDD Reliance Arrangements under the Amended AML/CTF Act & Rules?