RCA Group Services
AML Independent Review
Anti-Money Laundering
AML (Anti-Money Laundering) CTF (Customer Due Diligence and Terrorist Financing) encompasses a comprehensive and meticulous examination of a company’s Anti-Money Laundering policies, procedures, and systems. It is an essential process to ensure that organizations have robust measures in place to prevent money laundering and terrorist financing activities. As part of this process, conducting an independent review by an external consultant or organization not affiliated with the company is highly recommended.
The primary objective of an independent AML CTF review is to provide an impartial and objective evaluation of the company’s AML program. The review assesses the adequacy and effectiveness of the existing policies, procedures, and systems in place. It delves into various aspects, such as risk management practices, adherence to legal and regulatory requirements, and the overall efficiency of the AML/CTF processes and systems.
Regular AML CTF independent reviews are imperative for companies to ensure that their AML program remains up-to-date, effective, and compliant with the latest regulations and industry standards. By conducting these reviews on a periodic basis, organizations can identify any areas that require improvement, address gaps in their AML processes, and implement necessary enhancements to mitigate the risks associated with money laundering and terrorism financing.
The insights gained from the independent review serve as a valuable tool for organizations to enhance their AML program. By proactively addressing the recommendations and findings, companies can strengthen their risk management strategies, bolster compliance efforts, and safeguard against the ever-evolving tactics employed by money launderers and terrorist financiers. Ultimately, the aim is to foster a robust AML framework that not only protects the company from potential risks but also upholds the integrity of the financial system as a whole.
AML/CTF Review Content
- A review of transaction monitoring processes and procedures
- Monthly compliance training and testing results for staff
- Interview regarding Employee Due Diligence Program
- Anti-Money Laundering Questionnaire’
- Internal Control Assessment
- (CIP Form A) or equivalent for Customer Identification Procedures
- Know Your Customer (‘KYC’) checklist
- Enhanced Customer Due Diligence on Individual Customer or Representative of Company Customer (ECDD FORM A)
- Minutes of Directors/Senior Management Meetings
- Employee Hand Book
- Various AUSTRAC reports
- Review of the cheque book used for writing winnings from gaming machines
- Review of identification of winners
- Review of daily reconciliation reports from gaming machines
Independent Review
Who needs a review?
An independent review is an impartial assessment of Part A of your AML/CTF program. It checks that you’re complying with your program and that it: properly addresses your money laundering and terrorism financing risks, complies with your legal obligations, is working as it should.
Who needs to report?
Venues that are licensed for 16 or more electronic gaming machines, who do not provide any other designated services.
Member of a designated business group (DBG)
Any member of a DBG may lodge the annual compliance report on behalf of the whole DBG. If you are submitting a compliance report on behalf of all other DBG members, you will need to advise individual DBG members of the submission.
Compliance report
You must complete and submit the compliance report between 2 January and 31 March.
All questions in the compliance report refer to your business activities from 1 January to 31 December.
Do penalties apply for failing to submit an AML/CTF compliance report?
Yes. Failure to submit an AML/CTF compliance report can result in: an infringement notice (see s186B of the AML/CTF Act), or a civil penalty order (see s175 of the AML/CTF Act). Provision of false or misleading information in an AML/CTF compliance report is a criminal offence (see ss136 and 137 of the AML/CTF Act).What are the penalties for failing to submit an SMR to AUSTRAC?
If an SMR is submitted after the relevant reporting period or not submitted at all, AUSTRAC can apply to the Federal Court of Australia for a civil penalty order of up to $21,000,000 (100,000 penalty units) for a body corporate, and up to $4,200,000 (20,000 penalty units) for a person other than a body corporate.
AML/CTF Training
AML/CTF (Anti-Money Laundering/Counter-Terrorist Financing) staff awareness training refers to the education and training provided to employees on how to identify, prevent and report money laundering and terrorist financing activities.
The main objective of AML/CTF staff awareness training is to ensure that employees have a good understanding of the relevant laws and regulations, and are able to recognize and respond to suspicious activities. This type of training can include topics such as:
Understanding money laundering and terrorist financing: This includes a general understanding of what money laundering and terrorist financing are, and the reasons why they pose a threat to society.
Know Your Customer (KYC) procedures: This involves training employees on the importance of verifying the identity of customers, and the steps they need to take to ensure that the information they have is accurate and up-to-date.
Reporting suspicious activities: Employees should be trained on how to identify and report suspicious activities, and the importance of doing so in a timely manner.
Compliance with AML/CTF laws and regulations: Employees should be aware of the relevant laws and regulations that govern anti-money laundering and counter-terrorist financing, and the consequences of non-compliance.
It’s important for organizations to provide regular AML/CTF staff awareness training to ensure that employees are equipped with the knowledge and skills they need to perform their jobs effectively, and to maintain a strong compliance culture.
All reporting entities must provide money laundering/terrorism financing risk awareness training for employees.
This is compulsory. The training program must be documented in Part A of your AML/CTF program and help you make sure your business or organisation isn’t used to support criminal activity.
Staff Training
Why is it good?
You can rest assured that RCA’s Staff Awareness training covers all areas that are required by AUSTRAC.
Our training is interesting, current and dynamic to improve participation and recall by your staff.
All training is delivered online to provide maximum flexibility to your business. Staff can access the training from any internet connection and pause and return to the material as suits their schedule.
RCA’s Staff Awareness training is succinct and manageable and is appropriate for the pub industry. A complete module should take only 30 minutes.
All staff who successfully complete the course will be provided with their own individual certificate of completion as evidence of their training.
Staff Awareness Training
What is included in the RCA Staff Awareness training?
A 10 minute video on AML and how it affects gaming staff. The video is dynamic and interesting, and covers the important features of the new regulations, giving scenarios to illustrate concepts. A short reading section giving staff a summary of what is expected of them under the new AML laws. Followed by a quiz of multiple choice questions to ensure staff understand the concepts and can recall the important details.AML/CTF Training
What do you need to do from here?
RCA’s training staff will contact the customer to collect the names and email addresses of the staff members that will need training accounts. RCA will need the email address of the compliance officer to collect this information, and disseminate student results.