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(Not Legal) Advice from the AML & Financial Crimes Congress 2022

Friday 10 June 2022




A quick snapshot of what you may have missed if you weren't  able to the attend our AML & Financial Crimes Congress 2022:



  • There continues to be disconnect between risk assessments and product offering.
  • Do not overcomplicate  the risk assessment.
  • Flawed risk assessment methodologies can unfortunate consequences later.
  • Ensure AML & financial programs from third party providers actually fit your business model.
  • Ensure your transaction monitoring program continues to be relevant to your product offerings and business strategy—Review this often!
  • Only use resources to monitor things that you offer.
  • Ensure risk owners ( the business) have accountability of the financial risks as well as non-financial risks!
  • Try not to create too much friction for customers when building or reviewing your program.
  • Document everything!
  • Welfare fraud and identity fraud are some of  the key areas from the regulator.
  • Plan for the key person risk in in this time of the ‘great attrition.’
  • Make sure that you understand the nuances and regulatory expectations around know your customer, customer due diligence and enhanced customer due diligence.
  • The annual compliance report to Australian Transactions Reports and Analysis Centre (AUSTRAC) should be an enterprise-wide affair  based all of the above!
  • Reporting entities should not only be considering the evolving sanction regime but countersanctions from sanctioned states.
  • In sanctions also look out the attempts to sidestep the sanctions by mislabelling, mixing commodities, third party relationships that might have been sanctioned yet.
  • Do scenario mapping!
  • Continue to document everything!
  • Be aware of requirements around Applicable Customer Identification Procedures (ACIP ) when it comes to reliance and the case-by-case basis.
  • Most importantly keep an ear to the ground for the AML & Financial Congress 2022 debrief Podcast where we will touch on some of  the key themes of the event!