What does an AML/CTF Program look like for an accounting practice?
Every practice providing designated services must develop an AML/CTF program. Think of it as your playbook for managing money-laundering risk.
The legislation requires you to have two parts to the program
Part A: Risk Assessment, which forms the basis for identification of money-laundering risks and the design of controls firm-wide risk management —
Part B: Your policy and procedures for responding to the risks identified in Part A. This will involve appointing a Compliance Officer, implementing onboarding procedures, customer due diligence staff training.
What does this mean in practice?
AUSTRAC doesn’t provide much guidance here, because the Program is intended to reflect a ‘risk based’ approach – that is, each practice will take a different approach depending on their risk profile. Practically, this means small, low risk practices can implement streamlined policies, as long as risks are properly identified and managed. Larger and higher risk practices will need to tailor their approach accordingly.
The focus of the regulator will likely be less about what policy settings you have in place, rather the justification for these based on the risk identified – ie, are your controls a reasonable response to the risks identified in your practice?
Typical elements of a Program include:
Governance arrangements
Appointment of a Compliance Officer.
Customer Due Diligence procedures with low/medium/high risk tiers.
Escalation and suspicious matter reporting processes.
Training for all staff
Independent review
We can help with all of this – register for a webinar or give our AML/CTF team a call
Paul Gray
Principal
T 03 5225 5231 | M 0414 195 886
E pgray@ha.legal
Hugo Le Clerc
Senior Associate
T: 03 5225 5213 | M: 0438 089 334
E: hleclerc@ha.legal
