Firms can’t take shortcuts when building AML kits

Additionally, businesses should be starting to identify who will play the roles defined under the AML/CTF Act: the governing body, the senior manager, and, importantly, the compliance officer.

Last, businesses should think about how they on-board clients currently, and start to understand the changes they will need to make to those processes.

Taking shortcuts, Jeans warned, will cause headaches on a compliance front.

“The AML/CTF Act is clear: you must comply with all relevant obligations, and there’s nothing wrong with making sure compliance is aligned (where it can be) to current business practices or minimising the impact on client experience,” he said.

“However, there are minimum levels of compliance that need to be attained which cannot be the subject of shortcuts without exposing the business to regulatory non-compliance.”

When done properly, he said, the building of effective AML kits for one’s firm is not as overwhelming or onerous as it may first appear: “The AUSTRAC Starter Kits have been designed to reduce the effort, resources and therefore cost needed to achieve compliance.” 

“Saying that, the Starter Kits need to be actively engaged with and worked through, tailoring them to a particular business and the processes that work for them,” he added. 

“This will ensure that compliance is not only documented, but equally important, can be demonstrated and effective.”

Elsewhere, Jeans noted that there is “a lot of chatter” around what external solutions practitioners really need to be AML/CTF compliant. The answer, he said, depends.

“It depends on the nature of the business, as well as the size and complexity of the business.  It also depends on the trade-offs that a business wishes to make to increase efficiency and enhance a client’s experience,” he said.

“Before engaging with solutions providers, it’s vitally important that a business understand what it needs a provider for, how the solution will fit into current workflows, and what the cost benefit for the business is.”

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