Anti-Money Laundering reforms

We have worked with several businesses, ranging from wholesale retail to pharmacies, who have discovered they have inadvertently been providing limited loans that fall under the definition of designated services 6 and 7.

These businesses sought to normalise the situation and remediate their non-compliant position.

We supported them by designing a risk profile of previous activity, and then developing ML/TF risk assessments and AML/CTF Programs for the small part of their business that was providing designated services.

We have developed AML/CTF Programs and ML/TF risk assessments for a number of online gaming businesses subject to AUSTRAC scrutiny.

Whilst in the same industry and providing the same designated services, these required tailored responses to accommodate the nature, size, and complexity of each business.

These engagements also required the assessment of unique risk factors, such as payment channels, which required the adaption of risk assessment methodologies and the collection and assessment of unique data sets to understand the risk posed.

Grant Thornton has provided a wide range of AML/CTF services to clients in the precious metals and products sector. This gives us a holistic understanding of the unique intricacies that must be taken into consideration in this space. 

We have been engaged by one of Australia’s largest independent precious metal services group of companies, which includes several leading precious metal brands, including an online platform for buying and selling precious metals, Australia’s largest precious metals refinery, and other entities, including custodian vaults and a wholesaler and distributor of precious metals for the jewellery industry.

We have also worked with a number of precious metal dealers across Australia, supporting their AML/CTF compliance activities.

In 2017, digital currency exchange providers were subject to Australia’s AML/CTF regime for the first time in a bid to address an emerging ML/TF risk. 

We led workshops and supported 15 digital currency exchange providers to prepare for and meet new compliance requirements, including: 

• Risk assessment and management – establishing an approach and methodology to assess their  ML/TF risk, identify ML/TF risks in their operations and implement appropriate measures to mitigate and manage identified risks. 
• AML/CTF program – providers were required to develop and maintain an AML/CTF program. This program had to outline the procedures and controls in place to mitigate and manage the risks of money laundering and terrorism financing.
• Registration with AUSTRAC – how to prepare for and register with AUSTRAC before offering their services. This registration became mandatory to legally operate in Australia.
• Customer due diligence – how to identify and verify the identities of their customers. This included collecting and verifying information to ensure they knew who their customers were in a digital environment.
• Monitoring and reporting – providers needed to monitor customer transactions for suspicious activity and report any suspicious matters to AUSTRAC.
• Record keeping – how to keep and retrieve records of transactions, customer identification processes, and their AML/CTF program for a minimum of seven years.

Supporting the digital currency exchange involved undertaking detailed research on the structure of the sector, how they provide their services, and the type and nature of the ML/TF risks they face.

We have continued to provide support to digital currency exchanges since 2017 undertaking AML/CTF Independent Reviews as well as providing ML/TF Risk Assessments and AML/CTF Programs.