Looking towards the year ahead – 2021

We cannot believe it is coming to the end of the year! This year has certainly flown, we are still finding it hard to believe that in another six weeks it will be Christmas time. We want to thank all our clients for what has been a great year, and it is not over yet. There are the makings of another great year to come in 2021 for combatting Financial Crime.

AUSTRACs has set out its vision in its recently released 2020 – 2021 Annual Report. It is clear AUSTRAC’s focus in the new year will remain one where they will take enforcement action if it can be demonstrated that reporting entities are not meeting their compliance obligations and as a result expose the community to harm.

AUSTRAC will continue to work with overseas regulators and domestic law enforcement partners to combat child exploitation and online live distance child abuse following successes from its focus in this area in the last twelve months.

We should expect to see AUSTRAC continuing to work domestically and internationally with intelligence partners and continue to release guidance to educate and improve data quality received for intelligence and regulatory purposes.  With an increase in funding from this year’s budget AUSTRAC have already commenced a strong recruitment drive and are looking to replace its current systems and technology to improve existing capability.

So, with all that in mind, it is time to start thinking and planning what actions you should be putting in place for the year ahead. Here are a few things we think you should be considering:

  • Schedule your annual review of your Program and ML/TF Risk Assessment – make sure it considers any typologies, sector risk assessment and insights from recent enforcement actions
  • Plan your transaction monitoring rule review – if you are making changes to improve or decommission rules make sure the reasons are documented and signed off
  • Schedule your Independent Review if you are due one – make sure you are engaging right person and verify their independence (that is if we are not able to do it of course!)
  • Diarise your annual AUSTRAC compliance report, make sure you are engaging the right people early on to gather the right data required to submit an accurate report
  • Consider your resourcing capability, is it enough to manage your AML/CTF risks for the up and coming year? Do you need to get external assistance?
  • Do you have any outstanding risks that need to be addressed as a priority? Are they tracked and managed appropriately? Map them out and ensure you have captured any changes in ML/TF over the past year, especially with COVID 19
  • Update and schedule your training including role-based training – don’t just rehash last year’s training slides. Financial crime is ever-evolving, remember, criminals, are often always a step ahead. Consider whether your Board requires a specific education session to allow them to discharge their own obligations
  • Schedule regular reviews, oversight, and assurance activities. Plan control testing to ensure controls are operating efficiently and effectively to manage internal weaknesses and areas of vulnerability.

Have you identified any additions to the list above that you might require assistance with? Are there any priorities that you would like us to assist with next year? Let us know and we can schedule a workshop where required and help you plan your 2021 AML/CTF year.

And having done our own review we would like to inform our valued Compliance Counsel members that some of our rates will be increasing, effective 1 January 2021. The increase will impact our daily and hourly rates, as well as the fee for our standard independent review. At this time, our Compliance Counsel fixed fee will remain unchanged and any engagements that are already existing or entered into prior to 1 January will not be impacted.

If you have any questions or you would like to talk to us about our rate changes, please do not hesitate to reach out for a chat.

In the meantime, have a great weekend.

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