Date posted: 05/04/2022

Submission on AUSTRAC guidance for source of funds and source of wealth

CA ANZ submitted that the guidance is not required as existing customer due diligence and reporting obligations address the concerns raised

In the submission, CA ANZ outlined why the existing know your client, triggers to lodge a Suspicious Matter Report (SMR) or Threshold Transaction Report (TTR) and record keeping requirements are sufficient to mitigate concerns relating to source of funds and source of wealth of a client.

We also raised concerns with the draft guidance noting it lacked clarity on when further investigation would be required and the documents to be relied on.  Of particular concern, the listed sources of information to draw on for verification would require a client’s co-operation, yet you must not alert a client to any suspicions you may have.

If there is evidence that deeper investigation would better mitigate the risk of criminal activity, provide actionable intelligence for AUSTRAC, we suggested expansion of the existing ‘potential threats and red flags’ document.

In conclusion, we proposed that in place of more obligations on reporting entities, AUSTRAC move its focus to educating Australians to be prepared to verify their identity, source of funds and source of wealth when seeking to use designated services.

 

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