Reflecting on Your AUSTRAC Compliance Report

What is the AUSTRAC Compliance Report?

The annual compliance report is a self-assessment of your anti-money laundering and counter-terrorism financing (AML/CTF) compliance.

It is an opportunity to share with AUSTRAC how you are complying with your AML/CTF obligations and helps them to understand what assistance you might need, and governance changes they can make to facilitate.

AUSTRAC uses the information they receive to:

  • Measure the effectiveness of your AML/CTF compliance
  • Increase AUSTRAC’s understanding of ML/TF risks across different businesses and industries
  • Improve education and guidance

If you are reading this now, you have probably just gone through the process on AUSTRAC Online of filling in the questionnaire and submitting your answers to be compiled into a report. Alternatively, you haven’t ever done a yearly AUSTRAC compliance report and as a new reporting entity looking for some information on how to best prepare for the next one.

We have been in collaboration with ACAMS Australia and The GRC Institute to follow and assist compliance professionals to both understand and implement the changing nature of the compliance report in their respective organisations.

The changes to this years AUSTRAC AML/CTF Compliance has been well articulated in an article “Insights on AUSTRAC’s updated Compliance Report for 2019” by Lisa Dobbin and Chris Cass from Deloitte’s risk advisory team.

In this article, the authors highlight five key themes AUSTRAC is emphasising by making changes to the yearly compliance reporting procedures. To share one astute point;

“The increasingly quantitative nature of the questions suggests a more formal and data-driven approach is likely to be taken by AUSTRAC in the future when reviewing the Compliance Reports in their supervisory capacity, and starting to demonstrate a pivot in AUSTRAC’s focus towards the extent to which reporting entities are looking at the application of risk intelligence derived from, among other things, their sub-sector risk assessments.”

The team at bronID agree with this statement and will support AUSTRAC’s choice to prioritise taking a more data-driven approach to facilitating the best possible regulatory compliance framework for Australian reporting entities.

AUSTRAC’s enforcement actions against both Tabcorp and CBA highlight the need to improve our AML/CTF risk assessments and procedures. As seen in a recent blog post: A Lesson in AML CTF Governance the Royal Commission into Banking Report

Compliance Report Essentials

“We observe that, outside of legislative changes, many reporting entities have made limited changes to their AML/CTF program in the last 10 years.”Insights on AUSTRAC’s updated Compliance Report for 2019

Things to consider for your yearly Compliance Report

  • Data management and hygiene.
  • Building compliance reporting systems which preserve an individuals privacy, yet are open to being transparent when required.
  • Setting triggers to automatically update your AML/CTF Program and your compliance policy and procedures to reflect any relevant changes.
  • Setting triggers to automatically update your AML/CTF Program and your compliance policy and procedures to reflect any relevant changes.
  • Ongoing Risk Assessment of Customers.
  • Customise the policy and procedures to suit your business and products.
  • Recognising the cross over between the questions in the compliance report and the question your compliance officer should be addressed every day internally.

How can bronID help?

The bronID identity suite is a platform used to help you formulate and execute on your AML/CTF policies and procedures while aggregating your compliance data in one place.

bronID provides reporting entities with the tools to make both achieving your compliance obligations as well as reporting the relevant and necessary data to AUSTRAC straightforward and convenient. bronID can be your medium to help AUSTRAC take a more data-driven approach to fight financial crime and improve your own AML/CTF compliance procedures.

Written by
Mitchell Travers
A catalyst for transforming legislation and governance into easy to use software. The personified pen of bronID.

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