by Kit Legal | Mar 16, 2022 | AFSL, AML
AUSTRAC has released proposed guidance on source of funds and source of wealth. It provides some useful extra information on what AUSTRAC expects reporting entities to consider and document. What’s the difference between ‘source of funds’ and ‘source...
by Kit Legal | Mar 16, 2022 | AFSL, AML
As the physical horrors of war unfold in Ukraine, the global community has responded with an economic and financial war against the aggressor, Russia. The sanctions imposed on Russia by many countries, including Australia, are strict and punishing – and...
by Kit Legal | Jun 25, 2021 | AFSL, AML
Prepared by Catherine Evans and Rosie Jervis. There are changes to the AML/CTF Act and Rules that came into effect on 18 June 2021 that: clarify obligations to re-verify KYC information when you have doubts about the identity of the customer, beneficial owner or...
by Kit Legal | Mar 3, 2021 | AFSL, AML, Credit, Fintech, KitLegal, Privacy
Prepared by Rosie Jervis ASIC continues to focus its enforcement activities on holding financial services businesses to account for making false, misleading and deceptive representations. This week ASIC announced it...
by Kit Legal | Nov 16, 2020 | AFSL, AML
Answered by Rosie Jervis Please be aware that whilst you can outsource certain AML/CTF processes to an outsourced entity the compliance obligations under the AML/CTF Act and the reputational risk arising from non-compliance remains with you, as the reporting...
by Kit Legal | Nov 11, 2020 | AFSL, AML
Answered by Rosie Jervis. Short answer – yes you can, but you need an agency relationship in place and a contract that clearly details the roles and responsibilities of each party. You should also proactively monitor and test the outsourcing provider’s AML/CTF systems...