Joint submission on AUSTRAC guidance for alternate ID documents
AUSTRAC sought submissions on its draft updated guidance for using alternative identification processes under the anti-money laundering and counter-terrorism financing (AML/CTF) regime. These processes aim to assist customers who may have difficulty providing standard identification and who are assessed as low risk under the AML/CTF regime.
In a joint submission with CPA Australia and the Institute of Public Accountants we supported the intent of the proposed changes to ‘Assisting customers who don’t have standard forms of identification’ (the guidance).
We noted that the guidance is based on parties already in the AML/CTF regime and lacks clarity for, if the AML/CTF regime is expanded, new reporting entities such as our collective members.
We sought clarity on when alternate processes can be applied as the current guidance refers to essential financial services. We also raised concerns that such alternate processes are different to our members other statutory obligations, such a know your client obligations for the Australian Taxation Office, which may lead to confusion. Finally, noting that copies of identification documents do not need to be retained under the AML/CTF regime, we sought clarification on what elements of an alternate document should be recorded.
Our joint submission sought clarity on some issues in consideration of new reporting entities, such as professional service providers - our members, should the AML/CTF Amendment Bill 2024 become law.
