By Amy DaleyManager
26 October 2021
With continuous investment into the effectiveness of their intelligence function, timely expert insights from The Australian Transaction Reports and Analysis Centre (AUSTRAC), seek to provide much needed knowledge surrounding the prevention, detection, and disruption of Money-Laundering and Terrorism-Finance (ML/TF) risk.
Within the last 12 to 18 months, AUSTRAC have repeatedly advised that they expect organisations to go through their Fintel Alliance and other publications with a ‘fine tooth comb’. This includes making changes to their ML/TF controls as appropriate, and within a reasonable timeframe.
Recent publications from AUSTRAC include:
- ML/TF risk assessments by sector;
- Guidance for submitting more effective Suspicious Matter Reports (SMR);
- Financial Crimes guide with typologies, to help with prevention and detection of potential NDIS fraud; and
- Enhanced guidance and scenarios to help identify potential gaps in Customer Identification and Due Diligence Procedures.
What should you do to ensure compliance?
We continue to encourage our clients to ensure that they have a documented, succinct, and effective procedure in place to monitor, assess and action information received, inclusive of typologies, ML/TF thematic reviews, and industry guides.
Many entities provide evidence of regulatory feedback being assessed and actioned through stakeholder interviews, board/senior management meeting minutes, internal communications and training packs.
In addition, we would suggest that entities (if they have not already done so) develop a succinct and effective procedure to demonstrate compliance.
Procedures once developed, should include:
- Controls to mitigate existing key person reliance;
- A consolidated register that can be reviewed for completeness and assurance;
- A prompt to trigger review and enhancement of the ML/TF risk assessment; and
- How the organisation will review changes made to ensure they adequately address the intended risk(s).
With AUSTRAC’s sophisticated real time data monitoring and analytics capabilities, it is important that those providing designated services can demonstrate understanding and awareness of how their organisation has used regulatory and industry intelligence to enhance their ML/TF controls.
AUSTRAC have advised that in response to the November 2019 Fintel Alliance report, detailing typologies associated with Child Exploitation, they observed a three-fold increase in reported suspicious activity referencing transactions of concern.
In addition to being familiar with this publication, would your Board and Senior Management have a high-level understanding of the control enhancements that were made within your organisation, and their effectiveness?
If your answer to the above is no, the team at PKF can provide you with expert AML/CTF advice and support to deliver you a tailor-made, independent and effective review or advisory service that will provide your organisation with an accurate view of current state, along with value-add enhancement suggestions to help drive continued framework maturity, post our involvement.