Don't get on the wrong side of AUSTRAC
AUSTRAC places remittance providers, money service businesses and foreign exchange houses high on its watch list. We know because we’ve helped many companies - whether they're large, small, international or local - defend their Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Program and processes against AUSTRAC.
But the best way to avoid getting on the wrong side of AUSTRAC is to make sure that your AML/CTF Program is watertight.
Put in place a robust AML/CTF Program
If your business:
- Transfers money or something of value for, or on behalf of a customer
- Trades accounts for customers in foreign exchange
- Changes money or other currency
Then you must meet your obligations under the AML/CTF laws.
Remittance providers and foreign exchange businesses are generally considered high risk by AUSTRAC because they:
- Typically have a large number of transactions
- Operate cross boarders in high volumes
- May have many transactions that are undertaken through intermediaries
The first step to putting in place a robust AML/CTF Program is to conduct an AML/CTF Risk Assessment. This helps you identify your risks and determine how to mitigate them. Once your ML/TF Risk Assessment is complete, you can then put in place or review your existing AML/CTF Program. Your AML/CTF Program should:
- Identify what money laundering and terrorism financing risks your business faces
- Document your policies and procedures to mitigate those risks
- Put in place controls to manage those risks
Some crucial elements to your AML/CTF Program include:
- Know Your Customer (or Customer Due Diligence) processes. These make sure that you have verified who your customer is and can be either manual or electronic to suit your business model.
- Processes to identify critical threshold transactions and suspicious matters. You will also need to complete Threshold Transaction Reports, Suspicious Matter Reports and International Funds Transfer Instructions and submit these to AUSTRAC.
- Completing an Independent Review of your AML/CTF Program.
AML Experts can help you
Whether you're just setting up your AML/CTF Program or AUSTRAC is already knocking on your door, we can help you. We have worked with many remittance and foreign exchange businesses so we understand how differently you can structure your business and how your business model affects your AML/CTF risks.
We have helped TransferWise, Hi Hai Money Transfer, Goldmate, Velocity Trade, Encore FX and we can help you:
- Conduct a ML/TF Risk Assessment
- Develop your AML/CTF Program
- Put in place electronic verification processes to Know Your Customer
- Conduct an Independent Review of your AML/CTF Program
- Defend you against AUSTRAC
