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Modernising Australia’s Anti-Money Laundering and Counter-Terrorism Financing Regime

Deloitte’s response to the Attorney-General’s Department consultation

After nearly 17 years, and in the context of major structural shifts in the financial, technological and criminal landscape, alongside significant increases in the value of economic crime perpetrated and historically low percentage recovery of proceeds of crime, there is no question that reforms proposed to the Australian AML/CTF regime are now well and truly needed.

Industry and government are now well engaged in the immediate task of working through the detail to support the simplification of the regime. This will, of course, also increase the effectiveness of the regime. But, when we look around the globe, it is clear to us that Australia will rapidly fall behind our peers if more is not done to advance towards a far more progressive, ambitious regime which will incentivise and facilitate a broad and diverse ecosystem of participants to work together with a shared vision and plan to harden Australia against economic crime.

It will not be easy to achieve this and will require all stakeholders to the Australian AML/CTF regime to be courageous in thinking and acting for mutual success - but there are examples that we can learn from. Our submission lays out our perspectives of key initiatives that we believe are essential to lifting the effectiveness of the Australian regime, namely:

  1. A strategic vision for the management of economic crime at a regime level;
  2. The alignment of national ML/TF risk priorities and how the primary focus of REs needs to shift from maintaining technical compliance to a more outcomes-oriented approach;
  3. Greater efforts needed on the recovery of the proceeds of crime;
  4. Enhancing information and intelligence sharing by complementing the Fintel Alliance through private-to-private arrangements; and
  5. Harnessing technology for better risk intelligence through innovation.

We look forward to being part of the continuing dialogue around the reforms in the coming months. You can read our full submission, or just the Executive Summary, above.

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