AML Confirm AML/CTF Self-Assessment

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Development & Maintenance of the AML/CTF Program

The AML/CTF Act (2006) and Rules require that a reporting entity must develop and maintain a written AML/CTF Program that sets out its obligations under the AML/CTF Act and Rules and sets out how it addresses these obligations.

Do you have an AML/CTF Program?

Has your AML/CTF Program been reviewed in the last 12 months?

ML/TF Risk Assessment

Chapter 8.1.3 of the AML/CTF Rules requires that a reporting entity must consider risks posed by the customer types; the types of designated services (Products and Services); the methods by which it delivers designated services (channels); and the foreign jurisdictions with which it deals.

Do you have a ML/TF Risk Assessment for your business?

Has your ML/TF Risk Assessment been updated in the 12 months?

Does your ML/TF Risk Assessment include a inherent risk assessment of your customers?

Does your ML/TF Risk Assessment include a inherent risk assessment of the channels which customer access products and services?

Does your ML/TF Risk Assessment include an inherent risk assessment of the jurisdictions/countries in which your customers are located, your business operations are located, or where third parties are based?

Does your ML/TF Risk Assessment include a residual risk assessment after application of AML/CTF controls?

Does your ML/TF Risk Assessment include an assessment of the effectiveness of the controls set out in your AML/CTF Program?

AML/CTF Training

Chapter 8.2 of the AML/CTF Rules requires that an AML/CTF training program that is appropriate to the ML/TF risks faced is put in place by a reporting entity.

Does your AML/CTF Program include AML/CTF awareness training for staff?

Does your AML/CTF Program require AML/CTF training for staff when they join your business?

Does your AML/CTF Program require ongoing staff AML/CTF training?

Does your AML/CTF Program require additional AML/CTF training to staff in high-risk roles?

Does your AML/CTF Program set out the scope and frequency of training provided?

Employee Due Diligence

Chapter 8.3 of the AML/CTF Rules requires that risk-based systems to screen prospective employees and to re-screen existing employees who may be able to facilitate ML/TF, are put in place by a reporting entity.

Does your AML/CTF Program include employee due diligence?

Does your AML/CTF Program require due diligence on employees when they join the business?

Does the AML/CTF Program require ongoing due diligence on employees?

Does your AML/CTF Program set out the scope and frequency of the employee due diligence undertaken?

Oversight by Board and Senior Management

Chapter 8.4.1 of the AML/CTF Rules states that a reporting entity’s Part A program must be approved by its governing board and senior management. Part A must also be subject to the ongoing oversight of the reporting entity’s board and senior management.

Does your AML/CTF Program include oversight and governance by the board or equivalent senior management?

Does the AML/CTF Program set out the Board (or equivalent) process to approve the AML/CTF Program?

Does the AML/CTF Program set out the Board (or equivalent) process to approve the AML/CTF Program when it changes?

Does the AML/CTF Program set out how the Board (or equivalent) receive regular updates on compliance with the AML/CTF Program?

AML/CTF Compliance Officer

Chapter 8.5.1 of the AML/CTF Rules states that Part A of the AML/CTF Program must provide for the reporting entity to designate a person as the ‘AML/CTF Compliance Officer’ at the management level.

Does your AML/CTF Program set out the role and responsibilities of the AML/CTF Compliance Officer?

Does the AML/CTF Program set out the process for the Board (or equivalent) to appoint an AML/CTF Compliance Officer?

Does the AML/CTF Program set out the role and responsibilities of the AML/CTF Compliance Officer?

Has an AML/CTF Compliance Officer been appointed by the Board (or equivalent)?

Does the AML/CTF Compliance Officer hold a management position within the business

AML/CTF Independent Review

Chapter 8.6 of the AML/CTF Rules require that a Reporting Entity periodically commission an independent review of Part A of their AML/CTF Program. The review should assess the effectiveness of Part A of the AML/CTF Program, having regard to the club’s ML/TF risk; its compliance with the AML/CTF Rules; and the effective implementation of and compliance with the AML/CTF Program.

Does the AML/CTF Program set out the obligation to undertake an independent review?

Does the AML/CTF Program set out the scope and the frequency of the independent review?

Does the AML/CTF Program require that the person undertaking the independent review is truly independent of the development and/or operation of the AML/CTF Program?

Has the business commissioned an independent review in the last 2/3 years?

Customer Due Diligence

Chapter 4 of the AML/CTF Rules specifies the applicable customer identification procedures with respect to the various customer types which must be completed by a reporting entity. This included additional requirements in relation to Politically Exposed Persons (PEPs) and the beneficial owners of legal persons introduced in 2014.

Does the AML/CTF Program have a section setting out customer due diligence requirements?

Does the AML/CTF Program set out the requirements to collect a customer's identity information?

Does the AML/CTF Program set out the requirement to verify a customer's identity information?

Does the AML/CTF Program set out the steps undertaken to identify Politically Exposed Persons (PEPs)?

Does the AML/CTF Program address managing the three types of Politically Exposed Person (PEP) specified by the AML/CTF Rules: Foreign; Domestic; or International?

Does the AML/CTF Program set out criteria to identify high-risk customers?

Ongoing Customer Due Diligence

Chapter 15 of the AML/CTF Rules specify the obligations placed upon a Reporting Entity to undertake Ongoing Customer Due Diligence (OCDD) on customers. The OCDD is split into the following activities: • Enhanced Customer Due Diligence; • Refresh of Customer Identity Information; and • Transaction Monitoring

Does your AML/CTF Program set out your ongoing customer due diligence obligations?

Does the AML/CTF Program set out the obligations to undertake enhanced customer due diligence?

Does the AML/CTF Program set out the obligations to keep up to date customer identity information?

Does the AML/CTF Program set out the obligations to monitor transactions and/or customer activity/behaviour?

Enhanced Customer Due Diligence

Chapter 15.8 to 15.10 of the AML/CTF Rules specifies the applicable enhanced customer identification procedures with respect to the various customer types and circumstances.

Does the AML/CTF Program set out the obligations to conduct enhanced customer due diligence ?

Does the AML/CTF Program set out the obligations to conduct enhanced customer due diligence for customers that are foreign Political Exposed Persons (PEPs)?

Does the AML/CTF Program set out the obligations to conduct enhanced customer due diligence for customers that have been subject to a Suspicious Matter Report to AUSTRAC?

Does the AML/CTF Program set out the obligations to conduct enhanced customer due diligence for customers meeting the high risk criteria?

Does the AML/CTF Program set out enhanced customer due diligence for customers including an understanding of the source of funds/source of wealth of the customer?

Does the AML/CTF Program set out enhanced customer due diligence for customers including obtaining senior management approval to maintain the customer relationship/account?

Refresh Customer Due Diligence

Chapter 15.11 of the AML/CTF Rules, specifies the applicable ongoing customer identification procedures with respect to the various customer types.

Does the AML/CTF Program set out the steps taken to refresh customer identity information?

Does the AML/CTF Program set out to refresh customer identity information when certain trigger events occur?

Customer Activity and Transaction Monitoring

Chapter 15.4 to 15.7 of the AML/CTF Rules, specifies the transaction monitoring obligations placed on reporting entities. This includes putting in place appropriate transaction monitoring given the reporting entity’s ML/TF risks.

Does your AML/CTF Program set out the obligations to monitor your customer's activity and behaviour to identify unusual activity or behaviour that might be suspicious?

Does the AML/CTF Program set out 'red flag' activity behaviour by customers that indicates unusual activity and staff should be aware of and monitoring for?

Does the AML/CTF Program set out rules/scenarios that customer activity/transaction information and data are reviewed against which indicate unusual activity?

Does the AML/CTF Program set out a process for the review or investigation of activity and customers identified through monitoring activity?

AUSTRAC Feedback

Chapter 8.7.1 of the AML/CTF Rules states that Part A must include appropriate procedures for the reporting entity to have regard to any feedback provided by AUSTRAC in respect of the reporting entity’s performance regarding the management of ML/TF risk.

Does the AML/CTF Program set out the process to manage any feedback received by AUSTRAC?

Reporting to AUSTRAC

Chapter 8.9 and 11 of the AML/CTF Rules specifies the reporting obligations placed on Reporting Entities. This includes reporting Suspicious Matters (SMR); Threshold Transactions (TTR); and International Funds Transfer Instructions (IFTI).

Does your AML/CTF Program set out your AUSTRAC reporting obligations?

Does the AML/CTF Program set out the obligation to report Suspicious Matter Reports (SMRs) to AUSTRAC?

Does the AML/CTF Program set out the 3- business day for money laundering and 24 hours for terrorist financing timeframes to report an SMR to AUSTRAC?

Does the AML/CTF Program set out the obligation to report cash or cash equivalent Threshold Transactions (TTRs) to AUSTRAC?

Does the AML/CTF Program set out the 10 business day timeframe to lodge a TTR with AUSTRAC?

Does the AML/CTF Program set out the obligation to report International Funds Transfer Instructions (IFTIs) to AUSTRAC?

Does the AML/CTF Program set out the 10 business day timeframe to lodge an IFTI with AUSTRAC?

Does the AML/CTF Program set out the process for submitting the annual compliance report with AUSTRAC?

Does the AML/CTF Program set out the 31st March timeframe to lodge the annual compliance report with AUSTRAC?

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