The most effective compliance programs are built on simple habits done well. Understanding your obligations, knowing your risks and keeping good records can help your business meet its AML/CTF obligations.
Here are 5 top tips to help you stay on track.
1. Understand what applies to your business
AML/CTF obligations can vary depending on the services you provide, your customers and the risks you face. Understanding what applies to your business can help you focus on the requirements you need most and avoid unnecessary compliance gaps.
Example
A business who only deals with individuals will have different customer risks to consider compared to a business who deals with complex trusts and business structures.
Resources to help
2. Keep your AUSTRAC Online details up to date
Keeping your details up to date in AUSTRAC Online is a simple but important part of meeting your AML/CTF obligations.
We use the information in your account to contact your business about regulatory changes, reporting requirements, compliance updates and new guidance. If your details are out of date, you could miss important information that affects your obligations.
Changes to your people, contact details or business location should be reflected in AUSTRAC Online.
Why this matters
Keeping your details current helps ensure:
- important information reaches the right people in your business
- you receive updates about regulatory changes and reporting obligations
- we can contact you if there are issues with your enrolment, reporting or compliance requirements
- your business information remains accurate and up to date.
Example
If your AML/CTF compliance officer leaves the business and their contact details are not updated, important compliance updates and reminders may be sent to the wrong person. This could delay action on reporting requirements or changes to your obligations.
Resources to help
3. Know your risks
Criminals look for ways to misuse legitimate businesses. Understanding how this could happen in your business helps you put the right controls in place.
Your risks can change as your business grows, introduces new services or starts working with different customer groups. That's why it's important to review them regularly.
Example
A business that starts working with overseas customers may face different risks than it did when it operated only within Australia.
A remittance provider may identify unusual transaction patterns that need closer attention.
Resources to help
- National risk assessments and updates
- Risk assessment e-learning modules
- Risk assessment webinars
- Industry specific risk indicators
4. Get reporting right
Reporting is an important part of AML/CTF obligations and the reports you submit help us and law enforcement build a picture of criminal activity across Australia. These reports can support intelligence gathering, investigations and enforcement action. High-quality reporting also helps identify emerging threats and trends across industries.
Getting reporting right means understanding when you may need to submit a report, recognising potential warning signs and making sure reports contain clear and useful information
Good reporting isn't about proving that criminal activity has occurred. It's about recognising unusual activity, asking questions when needed and reporting suspicions where required.
Why this matters
The information your business holds may only be one piece of a much larger picture. Details that seem minor on their own can become valuable intelligence when combined with information from other reporting entities.
Example
A customer may provide inconsistent information about the source of funds for a transaction. Another customer may frequently change their instructions, use complex ownership structures without a clear business reason or appear reluctant to provide information about who ultimately controls a company.
While these behaviours don't necessarily mean criminal activity is occurring, they may indicate a need for further review and, where appropriate, a suspicious matter report.
Strong reporting processes can also help your business apply a consistent approach when unusual or suspicious activity is identified.
Resources to help
- Suspicious matter reports
- Threshold transaction reports
- Annual compliance reports
- Suspicious matter reporting checklist
5. Keep accurate records
Good record keeping is an important part of meeting your AML/CTF obligations.
Accurate records help you show how your business manages risk, meets its obligations and makes compliance decisions. They also make it easier to respond to audits, reviews or requests for information.
Records should be organised, easy to access and up to date. This includes documents that support customer due diligence, risk assessments, reporting decisions and other AML/CTF activities. Maintaining good records can also help your business identify trends, review the effectiveness of its controls and spot areas that may need improvement.
Resources to help
Compliance is an ongoing responsibility and by focusing on the basics and reviewing them regularly, you can build a stronger AML/CTF program.
More information
For more information on building your AML/CTF program and meeting your obligations, visit obligations and guidance. For guidance tailored to your sector, visit your industry.