Senior advisors of anti-money laundering (AML/CTF) compliance with considerable experience in advising institutions of all types of their AML/CTF compliance.
Financial services organisations are being put under increasing regulatory scrutiny related to AML/CTF compliance and their obligations under the Anti‑Money Laundering and Counter‑Terrorism Financing Act 2006.
Australian institutions, such as financial services firms; banks; building societies; credit unions; superannuation funds and gambling are obliged to comply by the act and are, therefore, realising the importance of implementing and maintaining a robust compliance program.
Great Minds provides AML/CTF programs tailored to an organisation’s specific requirements and obligations under the AML/CTF Act 2006.
Reporting entities must have an Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) program specifying how they comply with AML/CTF legislation.
The program must be a written document outlining how an organisation identifies, mitigates and manages the risk that their product or service is being used for money laundering and terrorism financing.
AML/CTF programs are a vital part of identifying, disrupting and preventing the illegal use of money in Australia. It is a requirement to have a written document outlining AML/CTF program before starting the provision of any designated services.
Below is our approach to putting together an AML/CTF program for Australian organisations:
Money laundering is the attempt to disguise the proceeds of illegal activity so that they appear to come from a legitimate source or activity.
Money laundering can take many forms, there are, however, three typical stages for money laundering.
In contrast to money laundering which involves disguising the original source of illegal funds, terrorist financing can be financed by legally derived money in order to carry out illegal activity.
The objective of money laundering is financial gain, whereas the objective of terrorist financing is to hide where the money will be deployed. For example, it is widely believed that the terrorist activities of September 11, 2001, were partially financed by legally obtained funds donated to charities.
Terrorist financing is a form of financial crime that uses funds to support the agenda, activity or cause of a terrorist organisation. Funds can come from legitimate sources, however, funds typically derive from criminal sources such as drug trade, weapons smuggling, fraud, kidnapping and extortion for illegal activity.
A Reporting Entity is an entity that provides a Designated Service under section 6 of the AML/CTF Act 2006. All reporting entities must meet obligations under the AML/CTF Act.
See: AML/CTF Act 2006 section 5
A Designated Service is a service that is listed in section 6 of the AML/CTF Act 2006. These are services that have been identified to possess a risk for money laundering and terrorism financing by AUSTRAC.
Designated services include a range of business activities in the financial services, bullion, gambling and digital currency exchange sectors. Entities that provide any of these services are reporting entities. Reporting entities have obligations under the AML/CTF Act.
See: AML/CTF Act 2006 section 6, tables 1–3
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