Deloitte Australia recently hosted its 4th Annual Financial Crime Symposium 2023 on 6 June in Sydney, and virtually, bringing together a diverse range of local and international speakers. There were a number of consistent themes throughout the Symposium, including the need for Australia to adopt a collective growth mindset concerning how we can collectively tackle financial crime, shifting from “tick the box” compliance with an increased focus on effectiveness, and focusing on meaningful change and reform outcomes that achieve a new level of maturity in respect of the local AML/CTF regime. The event profiled perspectives from AUSTRAC on its current priorities, the evolving relationship with technology in a post-industrial future, global talent initiatives, how the talent pool in Australia can be enhanced, and the changing sanctions environment.
The key takeaways from the event:
- The opening, a conversation with the Deputy CEO of AUSTRAC, focused on the evolving risks within the Australian financial crime environment and the importance of collaboration with key stakeholders to achieve the right changes and outcomes to Australia’s AML/CTF regime. Whilst the discussion centred around the proposed reforms and what functions the regulator will prioritise over the next 12 months, it was emphasised that accurate and timely data from the private sector, especially actionable financial intelligence law enforcement could rely upon, was key to disrupting organised crime in Australia. The notion of more robust governance and oversight mechanisms within reporting entities and at every level, as well as understanding the correlating risk appetite was emphasised, and the status of the highly anticipated Australian National ML/TF Risk Assessment was discussed.
- Our panel on global developments in financial crime (including a senior representative from Standard Chartered Bank and Deloitte’s Forum for Tackling Illicit Finance) emphasised there is a growing recognition that global initiatives are not always as effective as hoped in the fight against illicit finance, and since the COVID-19 Pandemic, there have been significant increases in areas such as fraud and scams worldwide. Continued efforts are required to effectively combat financial crime including public-private and private-private partnerships so that information can be shared at speed and scale, and the growing challenges between Privacy legislation and the current AML regime framework were considered. Focus was also drawn to the need for greater recovery of the proceeds of crime, given the current recovery rate is only approximately 1% globally, and it was emphasised that jurisdictions establishing national risk assessments are utilising data inputs to build capacity and capability into their AML program where it will have the greatest impact, ultimately resulting in better outcomes.
- Similarly, capacity and capability within the Australian talent market require further development, including attracting new talent into the industry so that the fight against financial crime is better resourced and more effective. A discussion panel (including a senior representative from CBA and former AMP senior regulatory lawyer) recognised the need to harness existing talent pools and collaborate with universities to ensure the skills required in the industry, such as data analytics, risk, and investigation, were being taught to the next generation.
- Consideration of capacity and capability at a global scale, namely in the Pacific, was discussed with senior representatives from the Fiji Financial Intelligence Unit, First Sentier Investors, and Asia/Pacific Group on Money Laundering where it was highlighted that capability needs to be built in the Pacific through local mentorship over the coming years. The establishment of permanent financial crime expertise in the Pacific is of key focus so that crimes such as corruption, cybercrime, and the process of narcotics trafficking can be interrupted, all of which impact our region.
- Reflecting on the sanction's environment twelve months on from the Russian invasion of Ukraine, the increased complexity of obligations for transnational companies and having to balance the jurisdictions in which they operate was emphasised. A discussion panel (including senior representatives from Suncorp Group, Deloitte Philippines, and Deloitte Singapore) observed the growing overlap between sanction obligations and Environmental, Social, and Governance (ESG), especially in respect of supply chains, highlighting a requirement to now take into consideration issues such as human rights and the corresponding consequences on business operations. Risk appetite was discussed at large, with country tolerance levels now needing to be determined in addition to understanding a country’s risk appetite; and the importance of considering the legal implications of the sanction environment was highlighted. Further, the growth and maturity of the sanctioned environment have seen an expansion outside of banking into sectors such as Energy, Mining, Wealth Management, and Insurance, and finally, we can expect local regulatory reforms to occur over the next twelve months.
We are already planning next year’s Financial Crime Symposium so that we can engage as a collective industry to discuss the progress, developments, and ways to tackle financial crime risk.
Many thanks to our speakers and panellists –
- Razim Buksh, Director, Fiji Financial Intelligence Unit
- Rob Coombes, Chief Compliance Officer, Affluent & Wealth, Standard Chartered Bank
- Carolyn Hanson, Global Head of Financial Crime Compliance, First Sentier Investors
- Dr. Gordon Hook, Executive Secretary, Asia/Pacific Group on Money Laundering (APG)
- Sonja Marsic, Partner at Norton Rose Fulbright, former AGS Senior Executive Lawyer
- Peter Soros, Deputy CEO, Regulation and Reform, AUSTRAC
- Lesley Symons, former AMP Group Financial Services (inc. Financial Crime) Regulation Lead
- Sharon Thorpe, Chief Operating Officer, Financial Crime Compliance at Commonwealth Bank
- David Wildman, Executive Manager Financial Crime, Suncorp Group
- Josh Black, Director – Forensic, Deloitte Australia
- Chris Bostock, Director, Deloitte Forum for Tackling Illicit Finance
- Chris Cass, Specialist Forensic Leader, Deloitte Australia
- Lisa Dobbin, APAC Financial Crime Lead, Deloitte Australia
- Dan Earp, Partner - Forensic, Deloitte Australia
- Peter Evans-Greenwood, Fellow, Deloitte Centre for the Edge Consulting
- Claire Franklin, Director, Deloitte Singapore
- Rob Gillow, Associate Director – Forensic, Deloitte Australia
- Amanda Lui, Partner – Forensic, Deloitte Australia
- Oliver May, International Development Practice Leader, Deloitte Australia
- Chris Noble, APAC Forensic Lead, Deloitte Australia
- Neal Ysart, Managing Director, Deloitte Philippines Forensic Leader