Resources & Blog
Risk-Based KYC: Bowling without the bumpers
For years, clear rules, box-ticking procedures, and safe harbour provisions made customer due diligence feel manageable—even comfortable. We believed prescription kept us safe. As we prepare for the new reforms, that comfort is quickly fading—replaced by a more fluid,...
Your Risk Appetite Isn’t What You Say — It’s What You Tolerate
Most organisations have a risk appetite statement, typically embedded in the enterprise risk framework, approved by the board, and reviewed annually. It often includes well-crafted phrases like, 'We have no risk appetite for non-compliance'. But here’s the...
Tipping Off Reforms: A New Shade of Grey?
A Compliance Officer’s worst nightmare ... A bank teller leans in and whispers to a customer: “They’re onto you, you might want to lay low for a while.” It’s exactly the kind of scenario tipping off laws are meant to prevent — the kind that prejudices an investigation...
AUSTRAC Compliance Reports: Practical Tips
Compliance reporting can feel as daunting as tax season, especially with new questions and heightened scrutiny from AUSTRAC in 2024. However, a proactive approach can transform this task from a headache into an opportunity to strengthen your compliance program....
Off the shelf AML/CTF Programs: Do they have a place?
With the introduction of Tranche 2 AML/CTF reforms, a wave of new, mostly smaller entities, lawyers, accountants and real estate agents are now grappling with compliance obligations once reserved for the Tranche 1 entities. For many of these organisations, the...
When Good Data Goes Bad: Data Quality Issues That Can Undermine AML/CTF Programs
Technology advancements in transaction monitoring, customer due diligence, and automated suspicious matter reporting (SMR) have strengthened AML/CTF programs, however one factor remains critical: data quality. Even the best designed AML/CTF programs can fail without...
Building Strong Regulatory Engagement: Practical Insights for Success
In today’s highly regulated environment, maintaining a positive and productive relationship with regulators is essential, especially in the AML/CTF space. Regulatory engagement is not just about compliance; it’s about building trust, demonstrating proactive risk...
What Makes a Good AML/CTF Program: A Practical Guide
Creating and maintaining an effective Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) program can feel overwhelming. Legal requirements, regulatory guidance, a myriad of internal risk management and governance frameworks, and several underlying...