Insights from our AML Experts

It is a fundamental principle of the AML regime that the Applicable Customer Identification Procedures (aka KYC, identification and verification) must be carried out before the commencement of the provision of a designated service for a new customer (AML Act, Sect. 32). That is unless the exemption in Sect. 33 applies.

During these uncertain times the law still applies and criminals are active. Transaction monitoring, investigations, and decisions around potentially suspicious matters still need to be made.

AML Experts are open for business by working from home. We are still able to assist you with our AML consulting, legal, and audit offering.

Crime and Punishment, or more accurately non-compliance and potential punishment. What will happen to AfterPay post the External Auditor's report and recommendations?

Guidance for AML/CFT Programme Audits was released by the New Zealand Department of Internal Affairs. Whilst not applicable in Australia it is informative with regard to Independent Reviews under AML/CTF Rule 8.6 (or 9.6) subject to the key differences between the two countries respective AML regimes.

Like the AfterPay Notice to Appoint an External Auditor, the Notice issued to PayPal takes a little deciphering, especially around the AML/CTF Rule numbers.

AML Experts are hosting a seminar on AML/CTF Program governance as part of the Under the Bonnet of the AML Act series.

The Afterpay Pty Ltd Section 162(2) Notice issued by AUSTRAC on 12th June 2019 is attached. Get reading!

ML Experts are hosting a seminar on Sect 41 Reporting Obligations as part of the Under the Bonnet of the AML Act series.