Contact: Karina Randall
Corporate Affairs and Communications
Deloitte
Mobile: 0414 823 712
Tel: +61 (0) 2 9322 3778

There are now less than three weeks before financial services and gaming companies will be forced to actively monitor transactions and manage the legal risk surrounding compliance requirements of the first tranche of the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Act, according to Deloitte Forensic Partner, Chris Cass.

Although the previous Australian Government granted a partial honeymoon period from aspects of AUSTRAC regulatory powers, providing strict criteria are met, overseas experience highlights the risk of reporting entities being involved or dealing with the proceeds of a financial crime incident.  Boards should ensure that that AML/CTF programs have not only been deployed but are functioning efficiently.

“Since the Act was adopted in December 2006, there have been extensive obligations to be complied with,” said Mr Cass. “The last of the formal deliverables is a transaction monitoring program, for which a process of management has to be in place by 12 December 2008.”

Mr Cass says that AUSTRAC has made it very clear that where electronic systems have been chosen but not implemented, reporting entities are required to have a manual control infrastructure in place to monitor all transactions.

“As a minimum, there are three critical aspects to implementing a transaction monitoring program going forward,” he said.

“The first of these is that a system need not be automated and given the circumstances, a manual system may be more effective.

“Secondly, staff training will prove to be critical to the effectiveness of the system, whatever system (manual or automated) is deployed,

“Finally, how outputs, in terms of suspicious matter reporting are managed, from the transaction monitoring system will be key.”

Mr Cass encourages clients to implement and embed transaction monitoring programs at the earliest opportunity.

“Based on overseas experience, this is one of the most difficult areas to consistently get right,” he said. “Entities should be starting with what their business requirements and risk objectives are before they launch into a solution, but training is a key component.”

Chris Cass
Partner
Deloitte Forensic
Tel: + 61 (0) 2 9322 7060