BAE Business Defence Forum Insights

The annual BAE Business Defence Forum held on the 11th September provided  an opportunity to hear from AUSTRAC’s Dr Nathan Newman, National Manager, Regulatory Operations.  A  few “nuggets” of wisdom imparted during the course of his address included:

  • highlighting a subtle shift in AUSTRAC’s regulatory approach from “helping industry to comply” to a more “forward looking appetite for enforcement” particularly where entities put their bottom line above their AML/CTF compliance obligations
  • an acknowledgment that AUSTRAC’s historical lack of enforcement action may have detracted from the necessary investment in AML/CTF Compliance
  • The need to simplify regulatory requirements by way of legislative reform – subject to Government priorities, this will take place over the next 2 years
  • Promoting a strong culture of AML Compliance in the community through increased communication and  raising awareness in relation to the intelligence gained from industry reporting

Further insights into this years Annual Compliance Report submissions which included 6,500 submissions (out of a reporting population of 14,000 + entities), included some 2000 + entities identifying potential or actual serious non compliance in the following areas:

  • oversight and accountability of Boards
  • insufficient resourcing of the AML / CTF Functions
  • Failure to adequately identify and manage AML/CTF Risks
  • Lack of AML assurance
  • Lack of ongoing due diligence
  • Lack of understanding of what activity should give rise to a suspicious matter reports

With the lack of AML assurance being called out as one of Dr Newman’s personal frustrations this should give you a clear indication of what the Regulator expects, and in reality, what your Boards should be insisting on in order for them to be able to demonstrate oversight over the effective implementation of the AML/CTF  Program.


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