Posted October 21, 2020
Posted By Meghann Cannon
AUSTRAC suspicious matter expectations confirmed.
Prepared by Rosie Jervis.
AUSTRAC has confirmed its expectations that entities must do more than simply report the suspicious matters they identify, they must also manage the risks identified.
AUSTRAC’s CEO states that there is ‘‘an expectation in the legislation that [entities] will have a very good understanding of the risk” and that they will ‘‘look at their own patterns in SMR reports and they will manage that risk accordingly.’’
Entities who identify specific risks or suspicious transactions as a part of their AML/CTF programs will not discharge their obligations simply by reporting these to AUSTRAC. They will need to demonstrate some consideration of that risk and show that they have taken appropriate action in response to the risk or the suspicious matter.