Tranche 2 high-level tips

This is about operational and compliance risk. Over the last 19 years I have advised on a few hundred thousand breaches of the AML/CTF Act (outside of the banking sector) and prepared, managed and embedded Australian compliance programs and dealt with AUSTRAC.

These are my 4 high-level tips for Tranche 2 businesses:

1. Understand your business and the risks inherent in it.

2. Understand your customers and the financial crime risks they present.

3. Do not be too confident in your risk assessment without external input.

4. Bring AML/CTF compliance to life in your business.

The business will need a risk assessment, a program, a compliance officer and so on. But those who go badly off rails with AUSTRAC almost always have all of this in place. Where they fail is on the basics of not understanding their own business, the risk in it and risks associated with their customers.