Our submission highlighted that our members are already held to high ethical standards through our professional standards. These standards already require our members to undertake customer identification and retain records.
Accordingly, we sought for the design of any new regulations to:
- not duplicate existing compliance obligations
- consider and reflect the cost impact on any, and each, proposed new sector, and
- stimulate participation rather than see services withdrawn to prevent breaching complex rules.
We shared the experience of our New Zealand members who have been adapting to Tranche 2 since 2018. The key learnings shared included:
- allowing an appropriate and reasonable time for implementation
- requirements to be scaled to reflect that risk is proportionate to the size of the business, and
- customer due diligence to accommodate digital options as the service provider may be geographically remote from their client.
Critically, any expansion to non-financial businesses and professions, such as accountancy, must recognize they are inherently different from the financial institutions currently captured under the regime.
We thank our members in Australia and New Zealand for your contributions to this submission.
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