We provide a comprehensive set of solutions for Authorised Deposit-taking Institutions' anti-money laundering (AML) and counter-terrorist financing (CTF) compliance in Australia, as well as authorised deposit-taking institutions' AML/CTF and ADI fraud prevention solutions in other major jurisdictions.
While governed by the Australian Prudential Regulation Authority (APRA) for their licensing requirements, the ADIs are generally considered to be designated services providers (an equivalent of an AML/CTF reporting entity) under the Australian Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act 2006). This means that ADI money laundering
This is our Australian non-bank deposit take AML/CTF page. Please see the following pages for AML/CTF Compliance Solutions:
- Anti-Money Laundering and Countering Financing of Terrorism Act 2009, for non-bank deposit takers in New Zealand.
- Money Laundering Regulations 2017, for Building Societies in the United Kingdom.
- Singaporean AML/CFT regulations for non-bank deposit takers (Finance companies) in Singapore.
- Bank Secrecy Act and Financial Crimes Enforcement Network (FinCEN) AML/CTF compliance for Savings and Loan Associations in the United States.
What ADI Types Do We Cover with Our AML/CFT Compliance Solutions?
Focusing on fraud, money laundering prevention and terrorism financing mitigation within the regulatory framework, our AML/CFT compliance and ADI fraud prevention solutions cover various types ADIs, including but not limited to:
- Retail ADIs
- Wholesale ADIs
- Credit Unions
- Building Societies
- Other Non-Bank Financial Institutions
Also, we offer AML/CFT Support for Related Financial Services to help resolve ADI money laundering, fraud and terrorism financing issues for the profit-making part of the business, including but not limited to trading, lending and funds management.
ADIs’ AML Advisory and Support
Our AML/CFT Advisory services for ADIs are comprehensive and tailored, including but not limited to:
- Advising on different aspects of AML/CTF: We offer ongoing guidance on AML/CFT compliance tailored to ADIs, including crucial aspects like customer due diligence, KYC onboarding, transaction monitoring, and managing money laundering and terrorism financing risks.
- Banking Relationships: Specialized advisory services focusing on the AML/CTF issues related to expanding banking relationships with major banks in Australia and overseas, ensuring compliance with partner financial institutions' requirements.
- Assisting Senior Management and Compliance Teams: We help ADIs' external senior management and compliance teams in managing relationships with external bodies such as AML/CTF auditors, supervisors, and law enforcement agencies.
- Peer Benchmarking and Best Practices: Enabling ADIs to compare their AML/CFT practices with industry standards and adopt best practices.
- Crisis Management and Remediation Support: Providing crisis management and remediation support in case of an AML/CFT breach or investigation, helping ADIs navigate through complex situations effectively.
- Handling Specific Clients: Advising on handling issues related to difficult clients, including onboarding high-risk corporates and managing enhanced due diligence (EDD) cases.
- Operational AML/CTF Advice: Offering advice to support and KYC teams on daily onboarding and support queue management, effective AML/CFT resource allocations, and operational improvements.
AML/CFT Training and Capacity Building for ADIs
- Customized Training: We provide specialized AML/CFT training focusing on ADI-specific requirements. This includes a deep understanding of the regulatory environment, ensuring that teams are well-versed in AML regulations and the nuances of working within the ADI sector.
- Regulatory Compliance Updates: Keeping ADI teams updated on changes in AML regulations is a key part of our service. This ensures that ADIs are always in line with the latest regulatory developments and compliance standards.
- Practical Workshops: We conduct interactive workshops to deepen the understanding of the ADI's money laundering landscape. These workshops cover important topics like financial crime, risk-based strategies, and customer identification programs, providing practical insights and strategies for compliance.
AML/CFT Policies and Procedures for ADIs
- AML/CFT Manuals: Developing and updating ADI-specific AML/CFT manuals is a critical part of our services. These manuals are focused on the prevention of specific laundering and terrorism financing risks, tailored to the unique operations of ADIs.
- AML/CTF Program & Policy Enhancement: We regularly review and enhance ADIs' AML/CTF programs and policies to ensure they remain compliant with the evolving AML CTF Act and reflect the latest trends in financial crime.
- AML Procedure Optimization: Our services include enhancing AML procedures to meet the specific needs of ADIs. This focuses on areas such as customer identification, ongoing due diligence, and ensuring that procedures are efficient and effective.
Comprehensive AML/CFT Managed Solution for ADIs
Acting as dedicated AML/CFT Compliance Officers (MLROs), our role encompasses overseeing all aspects of your AML Program for Authorised Deposit-taking Institutions (ADIs), including but not limited to:
- ADI-Specific AML/CTF Risk Management: Conducting detailed risk assessments for ADIs to identify AML risks and money laundering/terrorist financing (ML/TF) red flags. This involves a deep understanding of the ADI sector, including credit unions and wholesale ADIs, under the regulatory oversight of the Australian Prudential Regulation Authority (APRA).
- Managing KYC, Customer Onboarding and Enhanced Due Diligence: Implementing robust KYC and Enhanced Due Diligence (EDD) processes tailored for the unique requirements of ADIs. Emphasis is placed on thorough client scrutiny for high-risk clients and significant transactions, in line with AUSTRAC guidelines.
- PEP and Sanctions Screening: Our services include comprehensive screening against global sanctions lists and monitoring Politically Exposed Persons (PEPs), crucial for ADIs to mitigate risks associated with financial crimes.
- Transaction Monitoring and Reporting: Establishing ADI-specific ML/TF alerts and red flags to effectively detect and report suspicious transactions. This aligns with the AML CTF Act requirements, ensuring ADIs remain compliant with Australian financial regulations.
- Handling Information Requests from Law Enforcement and AML/CTF Supervisors: We assist ADIs in managing requests from law enforcement, AML/CTF supervisors, and other relevant entities. This includes liaising with banking partners and ensuring compliance with legal standards in information sharing.
Advanced AML/CFT Technology Integration for ADIs
- Digital Onboarding Compliance: We integrate advanced AML technology solutions to facilitate compliant digital onboarding processes for ADIs. This includes employing state-of-the-art systems for accurate customer identification.
- Transaction Monitoring Tools: Sophisticated transaction monitoring systems are implemented to effectively manage money laundering and terrorist financing risks in ADI operations. These tools are designed for detecting and reporting suspicious activities efficiently.
- Compliance Management Systems: We incorporate cutting-edge compliance management systems to streamline and enhance the efficiency of AML/CFT processes within ADIs. This ensures that ADIs remain compliant with the dynamic regulatory environment.
AML/CFT Audit Services for ADIs
- Compliance Auditing: Conducting independent audits to test compliance with anti-money laundering (AML) and counter-terrorist financing requirements is a key service. Our audits focus on critical areas such as CDD, SARs, and adherence to AML program requirements.
- Post-Audit Support: We offer post-audit support to ADIs, assisting with maintaining regulatory relationships and implementing recommendations following audits to ensure ongoing compliance.
- Regulatory Liaison: Managing communication with national AML/CTF supervisors and other relevant authorities forms part of our comprehensive service package, ensuring that ADIs are always aligned with the latest regulatory expectations and requirements.
ADIs’ Fraud Prevention Compliance Solutions
- Fraud Detection Systems: Implementing advanced systems for real-time fraud detection is essential in protecting ADIs from various types of financial fraud, including identity theft and transaction fraud.
- Preventive Measures: We set up proactive checks and alerts to tackle fraud risks specific to the ADI sector, including measures to prevent internal and external fraud.
- Fraud Awareness Training: Educating ADI staff about fraud risks is crucial. Our training programs cover various aspects of fraud, including identity theft, impersonation, and digital frauds, equipping employees with the knowledge to recognize and prevent fraudulent activities.
- Cover all common ADI fraud risks and specific fraud risks faced by a particular deposit take, including but not limited to:
Wider risk and compliance support requirements for Authorised Deposit-taking Institutions
- Multijurisdictional AML/CTF Compliance Support: for businesses that either offer non-bank deposit-taking services in more than one country or raise funds in one and invest/lend in another jurisdiction to streamline their AML/CTF compliance.
- ADI Licensing Compliance: Supporting applications for an Authorised Deposit-taking Institution (ADI) license from the Australian Prudential Regulation Authority (APRA) under the Banking Act 1959.
- Other financial Licenses. Apart from Australia, we can help an ADI with financial licensing into other jurisdictions such as:
- New Zealand: Secure a Non-Bank Deposit Taker License from the Reserve Bank of New Zealand (RBNZ) under the Non-Bank Deposit Takers Act 2013.
- United States: Acquire a license from the relevant state banking authorities, as non-bank lending is regulated at the state level. Compliance with federal regulations, such as those enforced by the Consumer Financial Protection Bureau (CFPB), may also be required.
- Singapore: Seek a license from the Monetary Authority of Singapore (MAS), complying with regulations under the Finance Companies Act for companies providing deposit-taking and lending services.
- United Kingdom: Obtain authorization from the Financial Conduct Authority (FCA) under the Financial Services and Markets Act 2000, particularly for firms engaged in consumer credit activities.
3. Oging Risk and Compliance Management: We offer an advisory and outsourced compliance management services for non-bank deposit-taking activities, focusing on:
- ADI Licesing Reqements APRA guidance and prudential standards and financial claims scheme requirements.
- Policy and procedural reviews.
- Outsourced provider's (vendor) onboarding/offboarding and monitoring.
- Risk, audit and compliance committees reporting
- Third-party assurance and internal audit requirements
- User Access Verification (UAV) control
- Procedures and controls testing and evaluations
- Compliance red flags and KPIs setting and tracking
General AML/CFT Obligations for ADIs in Australia
- Conducting thorough KYC checks: ADIs are required to perform detailed customer due diligence to verify client identities, focusing on beneficial ownership and legal entity customers. This is vital for maintaining robust AML/CTF compliance within the sector.
- Conducting ongoing monitoring: Establishing processes for continuous transaction monitoring is essential to identify and report suspicious activities. This is a key aspect of the AML CTF program for ADIs, particularly for those offering remittance services.
- Staff Vetting: Implementing comprehensive background checks and ongoing vetting of staff to maintain high standards of integrity and awareness in the financial services industry.
- Reporting Prescribed Transactions: ADIs have an obligation to report significant or cross-border cash transactions as per AML/CTF regulations, particularly crucial for credit unions and other ADIs under Australian regulations.
- Regular Staff Training: Providing continuous AML training to ensure employees are aware of AML/CTF protocols and can recognize money laundering risks.
- Timely Reporting of Suspicious Transactions: ADIs must ensure suspicious transactions are reported promptly to the relevant authorities as required by law, adhering to transaction reports guidelines.
- Risk Assessments: Conducting regular ML/TF risk assessments is crucial for ADIs, considering their specific operational models and customer bases.
- Independent Audits: Regular independent reviews of the AML/CTF program are necessary to ensure its effectiveness and compliance with Australian regulations.
- Applying Enhanced Due Diligence (EDD): For high-risk customers and significant transactions, especially for ADIs involved in larger or international transactions.
- Establishing Clear AML/CFT Policies and Procedures: ADIs must have documented guidelines that are regularly updated to reflect current AML laws and practices.
- Monitoring PEPs and Sanctioned Entities: Implementing measures for additional scrutiny of politically exposed persons and entities on sanction lists is critical for ADIs in Australia.
- Screening Against Watchlists: Regular checks against domestic and international watchlists are crucial for ADIs in maintaining compliance.
- Ensuring Proper Record-Keeping: Maintaining detailed and accurate records of client information and transactions is vital for compliance with AML/CTF regulations.
Which parts of AML/CFT are the biggest generic risks for ADIs?
- Inadequate Transaction Monitoring: Failure to effectively monitor transactions for money laundering indicators.
- Poor Compliance with AML Regulatory Frameworks: Inability to keep pace with evolving regulatory requirements.
- Risks in High-Value Transactions: Inadequate scrutiny of large or unusual deposit and withdrawal activities.
- Deficient Customer Due Diligence (CDD): Insufficient processes to accurately identify and verify customer identities.
- Non-Compliance in PEP and Sanctions Screening: Failure to effectively screen for Politically Exposed Persons (PEP) and adhere to sanctions lists.
- Lapses in AML Training and Awareness: Insufficient AML Compliance Training leading to staff unawareness of AML/CFT obligations.
What are some common ADI anti-money laundering failures during the customer onboarding process?
- Inadequate Customer Identification: Failure to effectively implement Customer Identification Programs.
- Risk of Overlooking PEPs: Not identifying or screening Politically Exposed Persons (PEP) adequately.
- Challenges in Assessing Transaction Patterns: Difficulty in predicting and monitoring future transaction patterns for AML compliance.
