About the 2020 compliance report

Did you offer designated services during all or part of the reporting period (1 January 2020 to 31 December 2020)? (Yes or No)

If No (you will only be presented with the Your feedback and Review and submit sections of the form):

Are you sure?

You have been enrolled as providing designated services during this period.

• If you offered any designated services during the reporting period, you must change the answer that you provided above.
• If you have stopped providing designated services and do not expect to provide designated services again, you must request removal  from the Reporting Entities Roll in addition to completing this form.
• If you have stopped providing designated services but are likely to provide designated services again in the future, you do not need to request removal from the Reporting Entities Roll. However, AUSTRAC may be in touch with you to understand your plans to recommence providing designated services.

Do you have less than 5 employees? (Yes or No)

Employee

A person who is employed full time or part time, or a casual staff member paid under contract or through wages or salary.

How did you provide designated services in 2020? (Select all that apply)

• ATM or IDM
• Electronic gaming machine
• Email
• Face to face
• Fax
• Mobile application
• Remittance platform
• Self-service gambling terminal
• Telephone
• Website
• Additional method(s)

IDM

Intelligent Deposit Machine, a type of advanced ATM that offers self-service transaction facilities which credits cash and cheque deposits to recipient accounts.

Mobile application

Is software often called an "App", designed to run on a mobile device, such as a smartphone or tablet.

Remittance platform

A system that enables funds transfers for remittance purposes.

If you are a remittance network provider, whose affiliates conduct transactions using your remittance platforms, you MUST select this option.

Self-service gambling terminal

A terminal at which customers can credit or withdraw from an account or place a bet or wager. Self-service gambling terminal does NOT include an electronic gaming machine.

Additional method(s)

Select this option if you provided designated service(s) using methods other than, or in addition to, those that are listed.

If you enter more than one 'Additional method', please separate them with a comma.

Were any of the above delivery methods introduced in 2020? (Yes or No)

Delivery methods

Channels through which your business provides or delivers the designated services.

Outsourcing

Outsourcing

Entering into an agreement with a third party to undertake aspects of the AML/CTF program on your behalf.

• Includes using any overseas businesses, even if that business is related to your business.
• Excludes using a domestic business that is related to your business.
• Excludes use of third party software applications and lists.

Did you outsource customer identification? (Yes or No)

If yes:

Was this function outsourced to multiple providers?

Business legal name of provider?

Was this function performed outside of Australia?

Was this function further outsourced by the service provider?

Multiple providers

Main provider

If this AML/CTF compliance function was outsourced to a number of providers, please enter the name of the provider who performed the highest proportion of this function.

Provider type

If this AML/CTF compliance function was outsourced to a large number of a particular type of provider (e.g. financial advisor, mortgage originator, etc.), please enter the type of provider instead of the business legal name.

Did you outsource AML/CTF program development? (Yes or No)

Outsourcing AML/CTF program development includes:

• outsourcing the initial development of your program
• outsourcing changes or updates to your program.

If yes: 

Was this function outsourced to multiple providers?

Business legal name of provider?

Was this function performed outside of Australia?

Was this function further outsourced by the service provider?

Multiple providers

Main provider

If this AML/CTF compliance function was outsourced to a number of providers, please enter the name of the provider who performed the highest proportion of this function.

Provider type

If this AML/CTF compliance function was outsourced to a large number of a particular type of provider (e.g. financial advisor, mortgage originator, etc.), please enter the type of provider instead of the business legal name.

Did you outsource transaction monitoring? (Yes or No)

If yes:

Was this function outsourced to multiple providers?

Business legal name of provider?

Was this function performed outside of Australia?

Was this function further outsourced by the service provider? 

Multiple providers

Main provider

If this AML/CTF compliance function was outsourced to a number of providers, please enter the name of the provider who performed the highest proportion of this function.

Provider type

If this AML/CTF compliance function was outsourced to a large number of a particular type of provider (e.g. financial advisor, mortgage originator, etc.), please enter the type of provider instead of the business legal name.

Did you outsource transaction reporting? (Yes or No)

If yes: 

Was this function outsourced to multiple providers?

Business legal name of provider?

Was this function performed outside of Australia?

Was this function further outsourced by the service provider?

Multiple providers

Main provider

If this AML/CTF compliance function was outsourced to a number of providers, please enter the name of the provider who performed the highest proportion of this function.

Provider type

If this AML/CTF compliance function was outsourced to a large number of a particular type of provider (e.g. financial advisor, mortgage originator, etc.), please enter the type of provider instead of the business legal name.

Do you have an AML/CTF program? (Yes or No)

If no:

AML/CTF Program

Sole trader or individual

If your business operates as a sole trader or an individual, you are still required to have an AML/CTF program.

Please explain why you do not have an AML/CTF program.

AML/CTF Program

Explain why you do not have an AML/CTF program

If yes: 
Has your AML/CTF program been approved? (Yes or No)

AML/CTF program approval

Approved program

Approved means adoption of the initial program or approval of changes to your program by your board, senior management or equivalent.

Sole trader

If your business operates as a sole trader or an individual, then the sole trader or individual will need to approve the program.

Governing board

If your business does not have a governing board, then your senior management will need to approve the program.

Was your AML/CTF program approved in 2020? (Yes or No)

If yes:
Did you make any changes to your AML/CTF program in 2020? Yes or No

If yes: 

What prompted these changes? (Select all that apply)

• AUSTRAC compliance assessment
• AUSTRAC enforcement action
• AUSTRAC feedback & guidance
• Change of AML/CTF Compliance Officer
• Changes to your ML/TF risk assessment
• Newly identified risks
• New designated service
• New technology or delivery method
• Regular scheduled review
• Internal review of systems or procedures
• Advice from industry body
• Advice from external consultant or service provider
• Media reports
• Independent review
• Changes to legislation
• Additional reason(s) for change

Changes to AML/CTF program

The events that prompted changes to the program. These may have occurred outside of the reporting period.

Media reports

Reports include, but are not limited to, newspaper articles, news websites, social media.

Additional reason(s)

Select this option if you have reason(s) other than, or in addition to, the reasons that are listed.

If you enter more than one 'Additional reason', please separate them with a comma.

Was Part A of your program independently reviewed in 2020? (Yes or No)

If yes:
What prompted this review? (Select all that apply)

• AUSTRAC compliance assessment
• AUSTRAC enforcement action
• AUSTRAC feedback & guidance
• Change of AML/CTF Compliance Officer
• Changes to your ML/TF risk assessment
• Newly identified risks
• New designated service
• New technology or delivery method
• Regular scheduled review
• Internal review of systems or procedures
• Advice from industry body
• Advice from external consultant or service provider
• Media reports
• Independent review
• Changes to legislation
• Additional reason(s) for review

Reasons for review

The events that prompted this review.  These may have occurred outside of the reporting period.

Media reports

Reports include, but are not limited to, newspaper articles, news websites, social media.

Additional reason(s) for review

Select this option if you have reason(s) other than, or in addition to, the reasons that are listed.

If you enter more than one 'Additional reason', please separate them with a comma.

How was the independent review conducted? (Internally/ Externally/ Combined/ Service provider type/ Accountant/ Lawyer/ Other)

Did you report internally on any of the following matters in 2020?  (Yes or No)

• AML/CTF risk awareness training statistics
• AUSTRAC feedback & guidance
• Independent review or remediation
• Performance of outsourced functions
• Newly identified risks
• Staff non-compliance with AML/CTF program
• Transaction monitoring information
• Changes to ML/TF risk assessment
• Other matters

Reporting internally

Means informing your board, senior management or equivalent through a recorded notification (e.g. email, written brief, attendance at a minuted meeting).

Other matter(s)

Select this option if you reported on any matter(s) other than, or in addition to, the matters that are listed.

If you enter more than one 'Other matter', please separate them with a comma.

If yes: (Select all that apply)

• AML/CTF risk awareness training statistics
• AUSTRAC feedback & guidance
• Independent review or remediation
• Performance of outsourced functions
• Newly identified risks
• Staff non-compliance with AML/CTF program
• Transaction monitoring information
• Changes to ML/TF risk assessment
• Other matters

Did you do an ML/TF  risk assessment  of your business in 2020?(Yes or No)

ML/TF

ML/TF means money laundering and terrorism 

If yes:
Was this risk assessment documented?

If yes:
What prompted this risk assessment? (select all that apply)

• AUSTRAC compliance assessment
• AUSTRAC enforcement action
• AUSTRAC feedback & guidance
• Change of AML/CTF Compliance Officer
• Newly identified risks
• New designated service
• New technology or delivery method
• Regular scheduled review
• New risk assessment methodology
• Advice from industry body
• Advice from external consultant or service provider
• Media reports
• Independent review
• Changes to legislation
• Additional reason(s) for risk assessment

Media reports

Reports include, but are not limited to, newspaper articles, news websites, social media.

Additional reason(s)

Select this option if you had reason(s) other than, or in addition to, the reasons that are listed.

If you enter more than one 'Additional reason', please separate them with a comma.

Do you have a documented process for conducting a risk assessment? (Yes or No)

What employee checks do you conduct? (select all that apply)

• Check licensing
• Open source searches
• Police checks
• Other qualification checks
• Reference checks
• Sanctions and PEP checks
• Social media review
• Additional check(s)

Employee check

Third party providers

You have also conducted a check if you use a third party provider for employee due diligence. Select the checks that they undertake on your behalf.

Open source searches

Information searches using publicly available sources on internet.

PEP

A PEP is a politically exposed person.

Social media review

Information searches on social network online platforms.

Additional checks

Select this option if you conducted checks other than, or in addition to, those that are listed.

If you enter more than one 'Additional check', please separate them with a comma.

Do you assess the ML/TF risk of individual roles in your business? (Yes or No)

ML/TF

ML/TF means money laundering and terrorism financing.

If yes:
Do you conduct different employee checks for roles with higher ML/TF risk? (Yes or No)

Employee check

ML/TF

ML/TF means money laundering and terrorism financing.

Did you provide AML/CTF training in 2020? (Yes or No)

AML/CTF training

If yes:
What AML/CTF training did you provide?

• Training for new employees
• Regularly scheduled refresher training
• Training on request
• Additional training

AML/CTF training type

Additional training type(s)

Select this option if you provided training other than, or in addition to, the types that are listed.

If you enter more than one 'Additional training', please separate them with a comma

Did you update your AML/CTF training program in 2020? (Yes or No)

Updates to AML/CTF training program

Includes changes to the content of training, the way in which the training was delivered, who it was delivered to, or how frequently it was delivered.

If yes:

What prompted this update? (select all that apply)

• AUSTRAC compliance assessment
• AUSTRAC enforcement action
• AUSTRAC feedback & guidance
• Changes to your ML/TF risk assessment
• New designated service
• Newly identified risks
• Internal review of systems or procedures
• New technology or delivery method
• Advice from industry body
• Advice from external consultant or service provider
• Media reports
• Independent review
• Changes to legislation
• Additional reason(s) for update

Media reports

Reports include, but are not limited to, newspaper articles, news websites, social media.

Additional reason(s)

Select this option if you had reason(s) other than, or in addition to, the reasons that are listed.

If you enter more than one 'Additional reason', please separate them with a comma.

Customers

What are your Customer types? (select all that apply)

• Individual
• Company
• Trustee
• Partnership
• Association
• Registered co-operative
• Government body 

Customer types

These are the types of customers that you provide designated services to.

Customer verification

Did you verify the identity of your customers in 2020? Yes/No/Not required

If yes:
How did you verify identity of your customers?

• Document based verification
• Electronic verification

Risk assessment

How many of your customers are high risk or above?

High risk customer

You are required to assess what you consider to be a high risk customer within your business. This assessment should be set out in your AML/CTF program. Factors that you should take into account include:

• The legal structure of your customer (i.e. individual, company, trustee)
• The beneficial owners of your customer (if applicable)
• The source of funds and wealth of your customer
• The nature and purpose of the business relationship with your customers
• The control structure of your non-individual customers
• The types of designated services that you provide
• The methods by which you provide designated services
• The foreign jurisdictions with which you deal.

Did you perform Politically Exposed Persons (PEPs) checks in 2020? (Yes or No)

Politically Exposed Persons (PEPs)

Where your business uses a broader PEP definition than that prescribed by the AML/CTF Act, you may choose to answer based on that definition.

How did you identify PEPs (select all that apply)

• Media review
• Open source searches
• Commercial database
• Sanctions lists
• Additional identification method(s)

Politically Exposed Persons (PEPs) identification

Where your business uses a broader PEP definition than that prescribed by the AML/CTF Act, you may choose to answer based on that definition.

Open source searches

Information searches using publicly available sources on internet.

Commercial database

A database of information developed and maintained by a commercial entity and made available to customers. This is the information for which you are likely to pay or subscribe for.

Additional method(s)

Select this option if you identify PEPs using methods other than, or in addition to, the methods that are listed.

If you enter more than one ‘Additional method', please separate them with a comma.

Unusual or potentially suspicious activity

Did your staff identify and report any unusual or potentially suspicious activity in 2020? (Yes or No)

Unusual or potentially suspicious activity

Your staff reporting

You or your staff may report unusual or potentially suspicious activity by escalating the matter to a specified person or area within your business or by submitting a suspicious matter report (SMR) directly to AUSTRAC.

If yes:
How did your staff report unusual or potentially suspicious activity? (select all that apply)

• Email
• Online form
• Paper form
• Submit SMR to AUSTRAC
• Verbal conversation
• Additional reporting method(s)

Reporting of unusual or suspicious activity

You or your staff may report unusual or potentially suspicious activity by escalating the matter to a specified person or area within your business or by submitting a suspicious matter report (SMR) directly to AUSTRAC.

Online form

A digital form that is accessible and editable online.

SMR

SMR means suspicious matter report.

Additional method(s)

Select this option if you report using methods other than, or in addition to, the reporting methods that are listed.

If you enter more than one 'Additional method', please separate them with a comma

Transaction Monitoring Program (TMP)

Do you have a TMP in place? (Yes or No)

If yes:

Did you review TMP rules in 2020?

Transaction Monitoring Program (TMP) rules

Any rules, logic or thresholds that are used to identify unusual or potentially suspicious transaction activity.

If yes:

What prompted you to review your TMP rules? (select all that apply)

• AUSTRAC compliance assessment
• AUSTRAC enforcement action
• AUSTRAC feedback & guidance
• Newly identified risks
• New designated service
• New technology or delivery method
• Regular scheduled review
• Change of AML/CTF Compliance Officer
• Changes to your ML/TF risk assessment
• High ratio of false-positives
• Advice from industry body
• Advice from external consultant or service provider
• Media reports
• Independent review
• Changes to legislation
• Additional reason(s) for review

Review of TMP rules

High ratio of false-positives

A significant proportion of the matters identified through a particular rule or threshold are deemed not to be suspicious.

Media reports

Reports include, but are not limited to, newspaper articles, news websites, social media.

Additional reasons for review

Select this option if you had reason(s) other than, or in addition to, those that are listed.

If you enter more than one 'Additional reason', please separate them with a comma.

If response to the question ‘Do you have a TMP in place’ is yes: 

Did your TMP identify any suspicious customer transactions that required further review in 2020? (Yes or No)

If yes:

Did you review these matters in any order of priority? (Yes or No)

If yes:

What factors were given priority? (select all that apply)

• Customer risk
• Jurisdiction risk
• ML/TF risk
• Product risk
• Transaction value
• Which rule or threshold was hit
• Additional factor(s) given priority

Jurisdiction risk

Risk associated with doing business with a customer located in, or transacting through, a foreign country.

ML/TF

ML/TF means money laundering and terrorism financing.

Additional factor(s)

Select this option if you had factor(s) other than, or in addition to, those that are listed.

If you enter more than one 'additional factor', please separate them with a comma.

Enhanced Customer Due Diligence (ECDD)

Did you conduct ECDD in 2020? (Yes or No)

If yes:

How did you conduct ECDD?(select all that apply)

• Extra information gathered
• More analysis of KYC information
• Verify or re-verify KYC information
• Verify or re-verify beneficial owner information
• More detailed analysis and transaction monitoring
• Senior management approval
• Consider whether to process transaction
• Additional method(s)

Conducting ECDD

Extra information gathered

Collection of extra information from the customer or third party sources to clarify already collected KYC or beneficial owner information, or to identify the source of wealth and funds of the customer and beneficial owners.

KYC information

Know-Your-Customer information.

Senior management approval

An approval by senior management for continuing the business relationship and the provision of a designated service to the customer.

Additional methods

Select this option if you used method(s) other than, or in addition to, those that are listed.

If you enter more than one 'Additional method', please separate them with a comma.

If no: 

Do you have an ECDD program in place? (Yes or No)

Were you required to submit reports to AUSTRAC in 2020? (Yes or No)

Reports to AUSTRAC

Reports include threshold transaction reports (TTR), suspicious matter reports (SMR), international funds transfer instructions (IFTI) and compliance reports.

If yes:

How did you ensure your reports were submitted on time? (select all that apply)

• Automated reporting system
• Regular monitoring and checks
• Scheduled reporting times
• Specialised reporting function
• System alerts or warnings
• Additional method(s)

On time

On time means within the timeframes specified in the AML/CTF Act and Rules.

Specialised reporting function

Select this option if transaction reporting was undertaken by a specific team or person who is not the AML/CTF Compliance Officer.

Additional method(s)

Select this option if you used method(s) other than, or in addition to, those that are listed.

If you enter more than one 'Additional method', please separate them with a comma.

If yes:

How did you ensure your reports were accurate? (select all that apply)

• Automated reporting system
• Compare submitted reports to internal records
• Compliance Officer reviews all reports
• Random sampling of reports prior to submission
• Random sampling of submitted reports
• Regular external audit of submitted reports
• Regular monitoring and checks
• Specialised reporting function
• Additional method(s)

Specialised reporting function

Select this option if transaction reporting was undertaken by a specific team or person who is not the AML/CTF Compliance Officer.

Additional method(s)

Select this option if you used method(s) other than, or in addition to, those that are listed.

If you enter more than one 'Additional method', please separate them with a comma.

Did you receive any guidance material or correspondence from AUSTRAC in relation to your business' compliance during 2020? (Yes or No)

If yes:
What did you do in response to this? (select all that apply)

• Communicated or escalated feedback internally
• Conducted training
• Increased AML/CTF resourcing
• Reviewed or changed AML/CTF program
• Reviewed or changed ML/TF risk assessment
• Reviewed or changed TMP rules
• Back-captured transaction reports
• No action required
• Additional action(s)

Response to AUSTRAC feedback

ML/TF

ML/TF means money laundering and terrorism financing.

Additional action(s)

Select this option if you took action other than, or in addition to, those that are listed.

If you enter more than one 'Additional action', please separate them with a comma.