AUSTRAC SMR and digital currency exchange provider webinar

>>Mr Tony Prior: Good
morning everyone. Welcome, and thank you for
attending our suspicious matter reporting and digital currency
exchange service provider webinar. My name is Tony Prior and I will
be facilitating today’s session. Today we’re lucky to be joined
by three AUSTRAC presenters; Daniel, Manager Intelligence,
Richard Lee, Director of Compliance and Wendy Freidman,
Senior Policy Officer. Today’s webinar will run for
about two hours and there are two parts to our session;
Part 1: What makes a quality suspicious matter report, and
Part 2: What digital currency exchange providers need to do to
comply with the new requirements. Each session will be followed by a Q&A, where you have the opportunity to ask
our panel questions. We have lots of information to
cover in our session, so we may not have time to answer all
your questions, however, we will follow up the questions if we
don’t have time to answer them today. You’ll also notice a link to
the survey on your screen. It will be great if you could
take the time to fill that in as your feedback is
important to us. Before we kick off, we thought
we’d take this opportunity to announce that, as a result of
recent CEO level engagement with several key reporting entities,
AUSTRAC intends to address a request for further education
on AML/CTF reporting and how it contributes to the government’s
strategy to target serious and organised crime. A prototype quarterly
publication incorporating reporting statistics,
intelligence usage and case studies will be designed by
AUSTRAC Intelligence within the Fintel Alliance in the coming
weeks with the aim of our first release in July 2018. So please look forward to that. Okay, so now that we’ve got
that, let’s get straight into it and handover to our first
speaker, Daniel, and suspicious matter reporting.>>Daniel: Thanks Tony. Good morning. My name is Daniel and I’m from
AUSTRAC’s Intelligence branch and I’m going to be talking
about suspicious matter reporting. But before we get into the
presentation, we’re going to have a quick poll question. It should be coming up
on your screens now. And the first question is:
If you are a reporting entity attending today’s webinar, have
you sent an SMR to AUSTRAC in the last 12 months?>>Mr Tony Prior: We’ll just
pause there for a couple of minutes while we wait for
those results to come through. And we can see now, we’ve had
some really good contribution across the sectors and we’ll
look at those results over the next coming weeks. Okay, Daniel?>>Daniel: Cool,
let’s get back into it. This webinar is a great
opportunity for AUSTRAC to be able to provide information and
guidance on what is a key factor in our ability to function
as Australia’s financial intelligence unit,
suspicious matter reporting. Suspicious matter reports, or
SMRs as I will refer to them throughout this presentation,
are some of the most information-rich sources of
financial intelligence we receive. They’re beneficial in commencing
investigations, supporting operations, understanding trends
and informing and influencing both AUSTRAC and our partner
agencies such as law enforcement and national security agencies. In today’s session I cover a
number of topics that all centre around SMR reporting. I’ll begin by providing an
overview of AUSTRAC’s operating environment in order to place
AUSTRAC and our reporting entities and the information
that is reported into the intelligence cycle. I’m going to highlight some
of the reasons why SMRs are so valuable. Then I’m going to give some
guidance about what to include and what not to include in
SMRs and provide some tips for quality SMR reporting. At the end of the session we’ll
have time for questions, which hopefully I’ll be
able to answer. Before I go any further,
I’ll just briefly handover to Richard, who will outline some
of the legislative requirements regarding suspicious
matter reports.>>Mr Richard Lee: Thanks, Dan,
and welcome to those online. Just a few points before
I proceed further. Firstly, it is important to note
that the requirement to lodge a suspicious matter report cannot
only arise when a service has been provided but also in
the circumstances of when a reporting entity proposes to
provide a designated service, as well as when a customer requests
a service or enquires as to whether a business would be
willing to provide a designated service. The obligation to report
a suspicious matter can be triggered under a number
of different circumstances. Firstly, it can arise if there
are reasonable grounds to suspect that the customer or
proposed customer is not the person they claim to be. It can also arise if a reporting
entity suspects on reasonable grounds that information they
have concerning the provision or prospective provision of a
designated service may be either relevant to the investigation or
prosecution of a person for an offence against the law of the
Commonwealth state or territory relevant to the investigation
or prosecution of an evasion or attempted evasion
of a taxation law. It may be of assistance in the
enforcement of the Proceeds of Crime Act or when the service is
preparatory to the commission of a terrorism financing or
money laundering offence. But it’s very important to
remember that there is quite a broad range of crimes and
activities that can trigger a reporting entity to report
a suspicious matter report. It is certainly not just limited
to money laundering or terrorism financing. In terms of timing, once a
suspicion is formed, a reporting entity has 24 hours to provide
a suspicious matter report to AUSTRAC if it is terrorism
financing related, and three business days for
all other matters. And finally, there are strict
secrecy rules regarding suspicious matter reports. An offence known as tipping-off
prevents the reporting entities disclosing that they have
reported an SMR, including disclosing it to the customer. Further detail, of course, is
available in our compliance guide, which is on
the AUSTRAC website. I’ll now hand back to
Dan for the next slides.>>Daniel: Thanks, Richard. Let’s kick off with the
operating environment. This diagram shows in very
simple terms the environment in which we operate. The arrows represent the flow of
information and interaction and, as you can see, the information
and interaction flowing from AUSTRAC to our reporting entity
population very much focuses on the regulation side of things,
monitoring and enforcement to ensure compliance. Now, while it is true that
much of a reporting entities interaction with AUSTRAC has
been compliance related, at this stage of the cycle we are also
providing feedback and guidance, which is what this
session is all about. This diagram does help to
explain the suspicious matter reporting cycle too. At the far end and the left of
the diagram we have criminals. They’ve committed or are
committing crimes, they’re interacting with reporting
entities, whether it be to facilitate their crimes, deposit
their ill-gotten gains, pay for or receive payment for illicit
goods and services, or they’re simply using the many services
on offer for their intended purposes, their
legitimate purposes. Just as AUSTRAC is monitoring
reporting entities for compliance, reporting entities
are monitoring their customers for indicators of potential
criminal activity. When this activity is detected,
and a suspicion is formed, the reporting entity will
lodge an SMR with us. Of course, that is not the
only reporting we receive. We also get the cash deposits
and withdrawals, instructions to send or receive
money from overseas. We get reports on the purchase
and sale of foreign currency, of gold bullion, gaming chips
and digital currency. This is depicted in the
arrow on the second circle. This is really the
reporting obligation. This is where AUSTRAC gets the
information from you that we turn into financial
intelligence. Within these reports we collect
a lot more than just an account number, a date, a name
and a transaction. We’re getting addresses and
identification documents, emails and phone numbers. We get points of data that
can be the missing pieces in investigations, the crucial
connectors in network building and, in the case of SMRs, we get
the benefit of 14,000 reporting entities using their industry
knowledge to monitor the financial system for
criminal activity. I will at times today speak
maybe a little too passionately about how interesting and
valuable suspicious matter reporting is, but that should
not undermine the value all the reports have that we receive. Each has the potential to be an
important piece of information, which is why we share that
information with our partners, and that’s the next circle. The movement of intelligence
and information to our partner agencies happens in
a variety of ways. The simplest is giving our
partners access to our database. All those reports that we
receive are houses in our database and authorised
officials from any of our 40-plus partner agencies are
able to search that system for their own needs. Our partners are numerous. We have the state and federal
police, tax revenue and social justice agencies. We have partners in border
protection and national security. This means that the information
contained in these reports we receive can be used to assist
in any investigation, from tax evasion to terrorism financing,
from fraud to insider trading, money laundering by serious
organised crime groups and romance and investment scams. In addition to just allowing
access to information, AUSTRAC provides financial intelligence
in a variety of intelligence products. These can be written at the
request of our partners but are often proactively sent after
activity has been detected by our monitoring and triage teams. Though not always the case, an
SMR is often at the centre of a proactive referral and a key
starting point for our analysis. From our partner agencies to
AUSTRAC, we see the arrow coming back, and we receive feedback
on our products, information on their priorities to inform out
monitoring and information about current trends in
criminal activity. When the system works the best,
we see not only the partner agency arrow coming back to
AUSTRAC to give feedback but also going all the way back to
disrupt and apprehend criminals. And from our point of view,
we certainly hope that AUSTRAC information was used
to lead to that arrest. In terms of the number of SMRs
we receive each year, it’s generally growing. Back in 2005 we received just
over 18,000 suspicious reports. By 2010 that had more than
doubled to 42,000 reports. And this had almost doubled
again by the 2014/15 financial year when we cracked
the 80,000 report mark. And though the numbers have
dropped off over the next couple of years, they’re back up
to record highs this year. With still a month and a-half
to go, we’re already over 96,000 SMRs for this financial year,
and we’ll surely be receiving over 100,000 by the end. And this makes sense because any
time you suspect a person to be involved in the commission of a
crime, as Richard said, against the Commonwealth state or
territory, or you suspect that they’re not who they say they
are, there’s that obligation to report. And there’s always new crimes
being committed, so the reporting builds up and
gets bigger and bigger. To deal with this, we have a
prioritisation system within our database that processes every
one of the reports and assigns a priority rating. This process surfaces the
reports that are most likely to relate to AUSTRAC or our partner
agency and whole of government priority issues. These reports are the ones that
are mostly like to form the basis of proactive referrals,
but that doesn’t mean the SMRs that don’t hit the highest
priority rules are not of value. SMRs can offer value in
so many different ways. The most obvious is that they
provide information on activity at that individual
transaction event level. They’re very much the
notification of something suspicious going on that
someone should investigate. In the best-case scenario that
we hope for, an SMR is reported, analysed, incorporated into
an intelligence product and referred to an agency, where it
leads to an investigation and an arrest or some kind
of disruptive result. So, an SMR that you lodge may
result in a terrorist attack being stopped, a shipment of
drugs being intercepted, and criminals being arrested. Here, SMRs can provide the
obvious, an explanation and highlighting of a party’s
suspect financial activity and they provide a wealth of other
information about parties that are involved in that report. There are phone numbers,
identifications, IP addresses, locations where they work,
business associations. The information in SMRs can also
corroborate and validate other information received through
other sources, whether it’s other SMRs or intelligence
reports, the SMR information can confirm relationships between
parties, identifications and addresses. All this information is
accessible by our partner agencies and able to be
cross-checked against their own data holdings. SMRs also have an
aggregate value to them. Viewed individually, they
may offer a tactical lead or information on a network but
viewed as a group over a period of time, they can be assessed
to discover trends and emerging threats. For example, we may see the same
kind of activity propagating across several different
reporting entities and similar types of products. And one indicator for further
analysis when in the triage process is when SMRs reporting
on the same person or group are received from multiple
reporting entities. SMRs also feature as part of our
other monitoring programs where, in combination with a certain
amount of other activity in our system, they’ll
raise a red flag. All SMRs have latent
value as well. The intelligence value may not
immediately be apparent, but they may be used in the future
as the subject of report comes of interest. An SMR doesn’t have to
immediately hit one of our monitoring systems and spark
an operation to be a good SMR. The information, even if it
doesn’t relate to high priority criminality at the time, can
hold important data when the parties involved escalate their
illegal activity or come to notice of law enforcement
through other sources. The info doesn’t even have to
relate to the suspected crime mentioned in the report. For example, there was a case
where an SMR put a person of interest in a time and place,
and that proved to be relevant in a homicide investigation, and
the report itself certainly had nothing to do with
homicide at the time. SMRs also provide information
that is otherwise invisible. So much of financial
intelligence, or all intelligence for that matter is
putting together a picture of what’s going on. AUSTRAC collects a lot
of reports and a lot of information, but there are so
many transactions we don’t see. When you write an SMR, this
contextual information is so important to completing a
picture that we wouldn’t get otherwise. Things like domestic transfers
between accounts or cash deposits and withdrawals and
amounts below the reporting threshold. And of course, there is the
human intelligence element that you see through your
interactions with the customers. That customer behaviour, as
long as it’s relevant to the suspicious matter, such as
changing explanations or having a nervous demeanour, adds to
the context and gives us a much better sense of the activity
and why it is suspicious. Before we go onto the next
slide, we’ll open up to a, to another poll question. And this one’s pretty easy. It should be coming
up for you now. The question is: What
is your industry sector?>>Mr Tony Prior: Thanks, Dan. We’ll just pause there for a
few seconds while we give the audience the opportunity
to answer that question. I’m just looking across now
and there’s some very quick responses coming across to us,
which will be very useful to us. We might continue, Dan.>>Daniel: Now we’re going to
switch our focus on how best to write reports. I hope I’ve convinced you
that there’s so much valuable information in them. When I think about SMR writing,
I think of an SMR being an intelligence product. And like any piece of
intelligence, it’s purpose is to influence a decisionmaker and it
needs to have all the necessary features of a good
intelligence product. It needs to be clear, timely,
relevant and accurate. These factors are often
difficult to balance. Making sure something is
reported quickly can influence its accuracy. So too can a report, focused on
being completely accurate, lose a little clarity in the
course of including all the information. The important thing to remember
is that intelligence provided after its useful time
loses much of its value. While I’ve said previously, SMRs
sit in our system for months, even years before their value is
realised, in matters where there would have been a chance of
intervention, the chance to seize cash or stake out a bank
or stop someone from leaving the country, timeliness is crucial. There’s a saying that 80% of an
intel product on time is better than 100% of one late, and
that applies to SMRs too. The clarify of an SMR comes into
play in the second point on the slide. It’s another
intelligence fundamental. SMRs should have the bottom
line upfront or the bluff. This means the first line of
the grounds for suspicion should explain just that; why
are you suspicious? Why is the SMR being reported? This is a lesson it took me a
long time in my career to learn. I always favoured writing with
probably too much of a dramatic flair, laying the background
of the activity out, then explaining how it had changed,
then bringing in some company links and then bam, bringing
up the criminal links I’d discovered on the
subject of my report. Now, why that may work for
novels, in the intelligence world those decisionmakers are
time-poor and the job is not to entertain them with dramatic
twists but to make it easy as possible for them to
make that decision. I should have, and now do open
with a known criminal is likely using company accounts to
launder the proceeds of crime, and then I explain the
background and the details later, having a clear, succinct
explanation of the reason for suspicion is also very
important, not just for the sake of clarity but for the
understanding of the people reading the reports. The AUSTRAC regulated population
covers a broad and diverse group of industries. No-one can be expected to be
an expert in the intricacies of each and every one of them. The general analysts rely on
reporting entities being able to explain the nature of their
businesses, what is normal for them and conversely, what is
abnormal about the activity they’re reporting in the SMRs. This expert knowledge that you
provide not only helps with analysis of individual
reports but understanding the overarching threats faced
by an industry group. This ties in with the last point
on the slide, including the analyst’s own
judgement in the report. All intel products should have a
judgement, a statement made with words of estimative probability
that says something is happening. It is likely that our customer
is attempting to avoid taxation. It is highly likely our client
engaged in insider trading. The customer is almost certainly
not who they claim to be as the ID presented was clearly false. Have faith in what you are
detecting, what you are seeing. Make a call about what it is and
include that judgement in the report. Also, if you’ve used open and
other information sources to come to your suspicion, please
reference them in the report. It adds to the overall picture
and adds weight to your judgement. The inclusion of relevant
component details is important because (a) the components feed
into our prioritisation and monitoring systems, and (b) the
transactions add to the picture, particularly if these
transactions are not otherwise reported to AUSTRAC. And being able to see them in
the reports really helps us understand the extent
of that activity. That ties in nicely with the
value of reporting what is otherwise unreported. I touched on this in the
previous slide, domestic transfers and cash transactions
that are below a reporting threshold add so much to the
context of the suspicion. Indeed, they are often the
cause of the suspicion. So, talk about them in the
report, include them as components, have them as an
attachment, let us know about them any way you can. I’ve spoken about how there
is great value in those little extra bits of information we
receive in our reporting, so please provide that; IDs, mobile
numbers, IP addresses, there are fields in the SMRs for all these
to be populated, so if you have this information,
put it in there. As I’ve mentioned earlier, those
observations that you make about their behaviour, who the
customers are interacting with, how willing they are to provide
information, how consistent the information they provide is,
this is gold for adding context and can be a determining factor
in whether a report is actioned or not. Put in your first-person
observations. They’re a great source
of intelligence. And that’s what we
do want you to do. Moving on, here’s what
we don’t want you to. And most of these are really
just the inverse of what we like to see in good SMR reporting. They’re things that detract from
the ideal reporting standard of clear, accurate, timely
and relevant SMRs. It seems odd to say it, but
we do get reports that explain things, that you can safely
assume AUSTRAC analysists and our partners know all about. The most obvious example is
including explanations of very well-known businesses, such
as explaining that Google is Australia’s leading
search engine. These unnecessary descriptions
of businesses that are widely known just take up space. And if there is something that
we don’t understand, we can always Google it. Similarly, links to websites
about popular businesses, such as gambling companies, major
retailers and major remitters, there are some things that are
enough in the public space that don’t need to be backed up
by evidence of your research. Repetition can have the opposite
effect of reinforcing a point, at least on paper. Given how I keep emphasising the
same points over and over again, I certainly hope it’s an
effective tool in presentations. But you only need to say your
statement of facts once in a clear manner. Not having the bottom line up
front is clearly not ideal, especially if the grounds
for suspicion is lengthy and complicated. Without that bluff, there is a
risk the point will be missed. The bluff allows the reader to
get some context immediately as to what’s going on before diving
into the rest of the report. On a more legal side of things,
do not attach inappropriate images. This is a very specific example. Stopping the sale and provision
of child exploitation material is a high priority for
Australian and international law enforcement, and we receive many
excellent SMRs detecting this activity. It’s enough to base your
judgement on whatever indicators raised that suspicion;
jurisdictions, profiles of sending and receiving customers,
the value of the transactions, and report that. There is no need to investigate
websites and be exposed to the material and there is certainly
no need, indeed, it is illegal to send it to provide examples
in imagery of this kind of activity as relates
to your customers. Also, do not provide the grounds
for suspicion as an attachment. Our prioritisation system relies
heavily on what is in the GFS and our system currently cannot
text mine for text that’s in attachments. If you’re putting all this
effort into writing an SMR, providing a clear and timely
explanation, this should be where we can see it and
where we can detect it. Because of the obligation to
report for any offence really, I can’t provide a full list of
crime types and indicators that need to be reported. But I can tell you that at a
very general level AUSTRAC’s priorities, as it aligns with
those of our government and our partner agencies. These priorities are in three
broad categories; national security, serious organised
crime and serious financial crime. In national security we’re
talking about terrorism and terrorism financing
primarily, but also sanctions, counter-proliferation,
countering foreign espionage and cybercrime. In the serious organised crime
space, we look into known criminals, large cash activity,
organised money laundering networks, which generally
includes the rapid movement of significant funds through
accounts and financial products. The serious financial crime area
often overlaps with the serious organised crime and here,
we’re looking into bribery and corruption, high-level fraud,
complex tax evasion schemes and corporate and security fraud. At the risk, as always, of too
much repetition, I’ll finish by reiterating the key points. SMRs are extremely valuable
pieces of financial intelligence and each one has the potential
to positively influence a criminal investigation. When reporting, please include a
key judgement or summary at the beginning of the GFS that
succinctly outlines the suspicion. The rest of the GFS can be
used to provide the information underpinning the judgement. And include all relevant
transaction component details. Please try to be as
succinct as possible. I know this isn’t easy, but when
working in an information-rich and time-poor environment, the
SMRs that can point us to the key pieces of information that
include the key elements for further analysis really pay off. So, keep on reporting. If you are a new reporting
entity, welcome, and start reporting. Take some lessons from today
about accuracy, timeliness and clarity and all the AUSTRAC
analysists and our partner agencies that rely on these
reports will thank you. And remember, it does not
reflect badly at all on a reporting entity to
be reporting SMRs. This does not indicate a
business is involved in criminal activity. If anything, it indicates that
you have a robust monitoring system and AML/CTF program. Also, SMRs are not
admissible as evidence. There are very strict laws that
control the use and access of SMRs by AUSTRAC and our
partners, and these are in place to protect you and all
our reporting entities. So that concludes
the presentation. I guess we’ll open
up to some questions.>>Mr Tony Prior: Thanks, Dan,
for that very comprehensive presentation on suspicious
matter reporting. Already we’ve got a lot of
questions coming through. The first one I’d like to
present to you: Is there a threshold of value that needs
to be met for a matter to be considered suspicious?>>Daniel: No, definitely not. As Richard pointed out in the
obligation section early on, you just have to suspect that
there’s a crime happening, that the person isn’t who they
say they are. It may relate to tax evasion. There’s certainly
no limit. If you’ve got to prioritise then high-value, and
we obviously look at high-value things, but any kind of
transaction, large or small that raises a suspicion should
definitely be reported.>>Mr Richard Lee: I think it’s
also worth mentioning as well that very small amounts of
course can be directed towards the most heinous crimes,
terrorism financing, and you mentioned child
exploitation earlier. So yes, it’s the crime,
not necessarily the amount.>>Daniel: Yes,
excellent point.>>Mr Tony Prior: Another
question coming through. How sure do we have to be that
a person is involved in criminal activity to report an SMR?>>Daniel: Not,
definitely not sure. I mean it’s one of those things
that in intel, we have the luxury of never,
never being sure. That’s why we use words of
estimative, probability. As long as your suspicion is
based on what you’re seeing and you back up what you’ve seen in
your report, then you don’t have to be sure at all. And the thing is with reporting
entities, you’ve got a very kind of vertical view of the
relationship with your customer, that business relationship,
so unless they’re a well-known criminal and it’s media reporting
on them, you really have no idea. But it’s those unusual
transaction activities that can come to AUSTRAC and then to our
partner agencies and where we have access to a lot more
information and we can fill in the gaps. We’ve got the other reports that
we look at and of course, our law enforcement partners have
their extensive records, so just that hint of a suspicion,
whether you, whether you know for sure, there’s certainly–>>Mr Tony Prior: So, on a knowledge continuum it’s
quite a low threshold?>>Daniel: Yes.>>Mr Tony Prior: Another
question come through: If a customer is deemed suspicious
and we report an SMR, do we need to end the business
relationship?>>Daniel: No. I mean every business has its
own AML/CTF program, or every reporting entity does. It’s got its own risk threshold. And they’ve got to be able to
judge for themselves whether they want to continue
with the customer. And AUSTRAC can’t tell anyone to
end that business relationship. As we said in the previous
question, just having the suspicion doesn’t mean that
you know for sure that they’re involved in criminal activity. You’re protected by the
reporting that as long as your obligation is to report on
activity, that’s where the extent of it goes.>>Ms Wendy Freidman: So, it is
up to each individual reporting entity? If you do not wish to continue a
relationship with the customer, you may terminate it. But you can also continue
because it might not be as high-risk or something like that
to continue that relationship.>>Mr Richard Lee: Yes, the Act
doesn’t require the relationship to end. Of course, you need to keep in
mind that if they do continue to do things that are
suspicious, to report that. And also, be mindful
of tipping-off. If the relationship has ended,
obviously you wouldn’t tell them the relationship has ended
because you reported to AUSTRAC.>>Mr Tony Prior: We’ve probably
got time for one more question. What if the transaction
doesn’t take place?>>Mr Richard Lee: Do
you still report—–?>>Mr Tony Prior: Yeah,
do you still report that?>>Daniel: Oh yes, definitely. Absolutely. You know, it’s just got to, the
suspicion has to be raised in the potential provision
of a designated service. It doesn’t actually have to go
through and, much like we were talking about whether you
include transactions that you’re not otherwise reporting, like
structured deposits, deposits that are below $10,000 and that,
not only should be reported but it can be the basis of your
suspicion, someone asking all these questions and enquiring
about a designated service and then not going through with it
when they’re asked for ID or, asked for explanation as to what
the transfer is for or their transaction is for and then
them pulling out of it. That can be the reason for
reporting, not only the – so definitely.>>Mr Tony Prior:
Thanks again, Dan. Well, that wraps up
our session on SMRs. And also, another reminder,
if you could take a couple of minutes to complete the survey
in the tab on your screen, that would be great. I’ll now hand over to Richard
and Wendy for the second part of today’s sessions; obligations
of digital currency exchange providers.>>Mr Richard Lee: Thanks, Tony. Welcome again to those online. We will now discuss the
obligations of the digital currency exchange providers
under the AML/CTF Act. We’ll start by explaining
some of the key concepts and definitions, then we’ll discuss
what is involved to enrol and register a business. We’ll take you through the
requirements of an AML/CTF program, which is your policies
and procedures to enable you to meet the AML/CTF requirements. We’ll discuss the reporting
requirements digital currency exchanges have, what needs
to be reported and when. We will conclude with an
explanation of the policy principles. They have been made to help
businesses transition to AML/CTF regulation. And it should be noted that we
will be covering quite a bit of ground during this session. Everything we discuss today is
available in more detail on our website in the form of guidance,
in particular the compliance guide. We will direct you where to find
the key pieces of guidance at the end of the presentation. And finally, we will also
hopefully have time for questions at the end as well. So firstly, I want to discuss
some key definitions and concepts. A business is considered a
reporting entity under the AML/CTF Act if they provide
a designated service. The Act now has over 70
designated services, including the latest one relating to
digital currency exchange providers. And these designated services
relate to a broad range of industries, banking, casinos,
money remittance, financial investments and many more. The new designated service at
item 50A is here on the screen and involves exchanging digital
currency for money, whether Australian or not, or exchanging
money, whether Australian or not, for digital currency where
the exchange is provided in the course of carrying on a digital
currency exchange business. And not surprisingly, the
customer is the person whose digital currency or
money is being exchanged. There’s a few key definitions
and concepts I’d like to discuss. The term ‘money’ is used. This is defined in the Act. And the definition of money
includes physical cash as well as money held on deposit
and in an account. Digital currency is defined as a
digital representation of value that meets certain criteria. The criteria being, there’s
four: the first one, must function, it must function as a
medium of exchange, a store of economic value or
a unit of account. It must not be issued by
or under the authority of a government body. It must be interchangeable
with money and may be used as consideration for the
supply of goods or services. And it must be generally
available to members of the public without any restriction
on its use as consideration. The wording in this designated
service limits the service to when it is provided to a
customer in the course of carrying on a digital
currency exchange business. The designated service,
therefore, does not include circumstances of, for example,
when a person simply exchanges digital currency to a friend or
family member, which is not part of operating a digital
currency exchange business. As the comparison in the Act,
the designated service at item 6 limits the making of a loan to
where the loan is provided in the course of carrying
out a loans business. So, the loans provided are for
non-commercial purposes, for example, within a family are
excluded and also loans made by a business whose core activity
is not the provision of loans are not captured. So, to be captured by this
designated service there must be a geographical link, link. To understand whether or not
a business has a geographical link, they must meet at
least one of three tests. And these tests, I won’t explain
now, but these tests relate to different circumstances of a
service being provided through a permanent establishment. The AUSTRAC compliance guide on
our website explains this and steps through the three tests
and provides examples to help businesses understand whether
the geographical link affects whether they are a
reporting entity or not. And there’s a number of
examples in the guide as well. So, you can see that this
definition does not capture the exchange of one digital currency
for another, such as exchanging Bitcoin for Ethereum. The exchange has to be between
Fiat or traditional currency and digital currency in
either direction. We’ll just pause there and
have another poll question. The question, and it should come
up on your screen now, is: What is your involvement with the
digital currency exchange? We’re just trying to gauge whom
in the audience is providing service now and those who
will be in the future. I will now head over to Wendy
though, who will be covering enrolment registration. Thanks, Wendy.>>Ms Wendy Freidman:
Thanks, Richard. Obligations for digital
currencies exchanges started on 3 April 2018. Businesses that are already
operating a digital currency exchange had until 14
May 2018 to register. Any business that starts to
offer digital currency exchange services after 14 May must
register with AUSTRAC before offering the service. You register your business by
completing and submitting an AUSTRAC business profile form
available on our website. There’s no fee to register. You’ll need to provide
information about the business, such as the business’s legal
and trading names, business registration numbers, such as an
Australian Business Number, an ABN, an Australian Company
Number, an ACN, the business structure, whether the business
is a company, sole trader, partnership, etcetera, the types
of services you offer to your customers and details of
business key personnel. Some examples of key personnel
are directors, beneficial owners and the AML/CTF
compliance officer. You will also need to obtain
National Police Certificates or a foreign equivalent for these
people and indicate who is the AML/CTF officer
for the business. The information about what you
need to complete the application is on the AUSTRAC website in
Chapter 5B of the compliance guide. And AUSTRAC will advise you of
the outcome of your registration application in writing. If your application is approved,
you will receive a registration number. And if we are considering
refusing a registration or imposing conditions,
you will be notified. Under the Act, AUSTRAC has up
to 90 days to make a decision. If AUSTRAC requires further
information about the application, the decision
must be made within 90 days of receiving that information. The decision period can also
be extended by an additional 30 days if the application cannot
be properly dealt with within 90 days. AUSTRAC, again, will notify you
in writing of any extension. Having said that, if there’s
nothing to hold up the registration application, your
business will be registered within 48 hours and entered onto
the reporting entity role and the Digital Currency
Exchange Register. At this stage, the register will
not be made public, however, in the future this may change. Also, if there are any material
changes to your business or it’s circumstances, for example, a
change of name, change of key personnel, ownership, et cetera,
you must notify AUSTRAC within 14 days of the event. This can be done through AUSTRAC
Online or by using the AUSTRAC business profile form. Your business will also need
to renew its registration every three years to enable it to
continue providing digital currency exchange services, and
AUSTRAC will send out a reminder when this is due. For this reason, your enrolment
and registrations need to be kept up to date. Now, an important note
about registration. Please remember that
registration by AUSTRAC of digital currency exchange
providers does not constitute an endorsement of that business or
certify its compliance with any anti-money laundering and
counter-terrorism financing obligations. Businesses must not use their
registration status in any way that suggests AUSTRAC or the
Commonwealth Government endorses the business or any of
its services or products. Words including ‘endorsed’,
‘approved’ or ‘licensed’ are examples of
inappropriate wording. So, to be clear, this means no
using our logo on your website, no claiming you are affiliated
with AUSTRAC and no statements like we are officially licensed
by AUSTRAC as a digital currency exchange. However, if your business is
registered, stating that you are registered is okay. I’ll now hand back to Richard,
who will cover AML/CTF program requirements.>>Mr Richard Lee: Thanks, Wendy. Before I go on, our final poll
question, the question should come up on your screen now. After information around your
experience today with AML/CTF obligations. So, the question is: Do you
have any prior experience with AML/CTF obligations? We have conducted a number of
workshops around the country and we did see a real broad range
of background and knowledge, so we’re interested to know where
the audience is at with that. I’ll just pause until the
answers are coming in hopefully.>>Mr Tony Prior: Yes, they’re
flowing through now very quickly. So, thank you for all the
audience participating in that poll.>>Mr Richard Lee:
So, we’ll move on. I want to discuss the
risk-based approach. Generally, there are two main
approaches to regulation; a prescriptive approach, where the
Act tells you exactly what to do, there’s little flexibility
for businesses on how they will meet that obligation. And a risk-based approach,
principles approach, where the Act provides you with general
principles and you have the flexibility to build processes
to meet the obligations based on the risk of your business. The AML/CTF Act is considered
risk-based legislation, and you’ll see
references in both the Act and the Rules where obligations are
to be met through appropriate risk-based systems and controls. In developing these systems
and controls, digital currency exchanges must have regard to
the nature, size and complexity of its business and the
type of ML/TF risk it faces. And if other reporting entities
are still online, then obviously it applies to them as well. A risk-based regulatory approach
recognises that those being regulated have the experience
and knowledge to assess and manage their risk. It also helps to reduce
regulatory costs by focusing resources on the
higher risk face. Undertaking a sound ML/TF risk
assessment is the cornerstone to meeting obligations
under the AML/CTF Act. It is what will determine your
practices to mitigate and manage ML/TF risk in the form of
AML/CTF program, which we’ll discuss in more detail today. I just want to briefly talk
about an enforcement matter last year. Tabcorp paid a civil penalty of
$45 million dollars last year as a result of contraventions
of the AML/CTF Act. In his judgement, Justice Perram
provided the following in regard to the AML/CTF Act. He said in Australia the
parliament has decided that it will pursue the
risk-management approach. It will be seen that this
regulatory decision by the parliament put at the heart of
the scheme of regulation the concept of AML/CTF programs,
which will be monitored by the regulator AUSTRAC. In a sense, it involved the
reposing in industry of a degree of trust for its operation of
the AML/CTF risk-management system. And the Act deals severely
with breaches of that trust. So, Justice Perram highlighted
the role of an AML/CTF program in the risk-management approach
and we will now give you an overview of what the AML/CTF
program must contain. There is obviously more detailed
information about AML/CTF programs on our website. The two key pieces of guidance
that will assist you are the AUSTRAC compliance guide, which
relates to all businesses we regulate, and a specific digital
currency exchange industry guide that will assist you in
developing and implementing an AML/CTF program. I’ll provide the relevant links
to that guide at the end of the webinar. Your AML/CTF program should
be seen as your policies and processes of how you will meet
your obligations to identify, mitigate and manage
your ML/TF risk. Its purpose is not only to
identify certain activities that need to be reported to AUSTRAC,
but also to protect your business from being
exploited by criminals. The first step is to undertake a
risk assessment to identify your ML/TF risk. The four key areas you need to
consider are the type of service you are providing, how
the service is provided. For example, are you providing
it face to face or online, your customer types, so what
type of legal entities. For example, that you’re
operating, you’re dealing with, individuals or companies, and
the jurisdictions your business is willing to operate in. Now, the guide steps you
through how to undertake that assessment. We also have other guidance
about risk management available. And I’ll also provide that
link at the conclusion of the webinar. We cannot stress the importance
of undertaking a quality risk assessment. The assessment will identify
what your risks are and will drive the content of your
AML/CTF program and how you will mitigate and manage
the identified risk. It’s also important to keep in
mind that risk does not stay the same. It constantly changes as changes
to both your internal and external operating
environment occur. An AML/CTF program needs to be
approved by the board and senior management, who must also
subject it to ongoing oversight. It’s essential that the
leadership of an organisation are aware and take ownership of
how the business is mitigating and managing it’s ML/TF risk. An AML/CTF compliance
officer must be appointed. They must be at management level
and can undertake other duties. The compliance guide provides
information on the duties of a compliance officer. The AML/CTF program must
document its employee due diligence procedures, which
relates to the screening of staff to minimise exposure
to risk, both for prospective employees and when to
re-screen an existing employee. The program must also include an
AML/CTF risk awareness training program for employees. This should also extend to
include board members, senior management, agents and
consultants who carry out functions connected with
providing designated services. The risk awareness training
should ensure that employees are aware of the ML/TF risk faced by
the business and their role in mitigating this risk by
contributing to the reporting the entity’s overall compliance
with it’s AML/CTF obligations. Procedures must be included as
to how AUSTRAC feedback on the digital currency exchanges
performance in managing ML/TF risk will be dealt with. And the program must include
the reporting obligations and systems controls designed to
ensure compliance with them. And this obviously includes
suspicious matter reports, threshold transaction reports,
compliance reports, as well as changes to enrolment and
registration information. Ongoing customer due diligence
must be included in the AML/CTF program. This involves a transaction
monitoring program that monitors customers for the purpose of
identifying transactions that are considered suspicious and
identifying complex, unusually large transactions and unusual
patterns of transactions. It also includes enhanced
customer due diligence, which is the process of undertaking
additional customer identification and verification
measures in certain circumstances that are
deemed to be high-risk. The guidance goes into more
detail obviously, including what may form part of your monitoring
and what may be undertaken as part of these procedures. The guidance also steps through
what is required to satisfy the know your customer obligations,
including if a customer is a politically exposed person. That includes what needs to
be collected and verified and different requirements,
depending on the type of customers you are dealing with. For example, whether the
customer is an individual or a company. The AML/CTF program must be
subject to regular independent review, and this includes its
effectiveness in addressing ML/TF risk, whether it complies
with legislation, whether it has been effectively implemented
and whether the business has complied with the program. And finally, the guidance
explains what records must be kept and for how long. So, as you can see, the AML,
AML/CTF program is your key tool to preventing your business
from being exploited by criminal behaviour and, of course,
identifying when it does. I’ll just handover now to Wendy,
who will now cover reporting.>>Ms Wendy Freidman:
Thanks, Richard. So, reporting. There are four reporting
obligations under the AML/CTF Act. The number of obligations for
your business depends on the types of services known as
designated services offered to customers. The majority of digital currency
exchanges will just have three reporting obligations;
suspicious matters, threshold transactions and AML/CTF
compliance reports. Suspicious matter reports, SMRs,
must be made to AUSTRAC when a digital currency exchange
forms a suspicion on reasonable grounds that a matter
may relate to an offence. Such offences include money
laundering, the financing of terrorism, proceeds of crime,
tax evasion, a person who is not who they claim to be or any
offence under Australian Commonwealth state
or territory law. The types of criminal activity
an SMR may relate to is very broad. It’s not just about money
laundering or terrorism financing. And as Dan said earlier, we see
SMRs that relate to a vast array of crimes, including fraud, drug
trafficking, human trafficking, scams and many more. As we stated in an earlier
session, a suspicious matter report must also be lodged when
the reporting entity suspects on reasonable grounds that the
customer or proposed customer is not the person they claim to be. It is also important to note
that reports be made not only when a service has been
provided, but also in the circumstances of when a person
requests a designated service or enquires about whether an
exchange would be willing to provide a designated service. An exchange does not have to
establish the exact nature of the criminal offence the
customer may be involved in and further, your staff would not
be expected to know or do, or to establish that funds or property
have been acquired through illicit or criminal means. It should also be noted there is
not threshold dollar amount for reporting SMRs. The industry guide for the
digital currency exchange sector provides you with some example
of what should be considered to be reported as a
suspicious matter. The next reporting obligation;
threshold transaction report, or TTR, must be made to AUSTRAC
when a digital currency exchange accepts or pays out physical
cash of $10,000 or more or the foreign currency equivalent. This does not apply to
electronic funds transfers. An AML/CTF compliance report is
an annual report which involves answering questions in regards
to how a business is meeting it’s AML/CTF obligations. Historically, this report has
been required to be provided by the end of March. A series of communications are
made by AUSTRAC in the lead up to ensure that you
meet any deadlines. So again, please keep your
enrolment and registration information up to date so we can
inform you of when your, your compliance report
obligation report falls due. Now we’re going to talk
about reporting periods. Threshold transactions, 10
business days from when the transaction took place. Reporting obligations for
digital currency exchanges commenced on 3 April 2018. This means if you formed a
suspicion before 3 April you cannot report it. But do report it if suspicious
activities continue from that date. Only threshold transactions
conducted from 3 April onwards can and must be reported. The next slide, we talk about
the report types and reporting methods. Reports must be submitted on
approved forms by approved methods, which means you
must use the form format and reporting method
AUSTRAC specifies. Do not email reports to us. No telling us just look up the
transaction on the block chain. The reporting obligations are
not just about the transaction. You are also required to report
what you know about the parties involved in the transaction and
the source and destination of funds. There’s one suspicious matter
report type for all reporting entities to use and there
are four types of threshold transaction reports, depending
on industry type or designated services provided. Digital currency exchanges
will be using the threshold transaction report financial
and bullion services form, or in short TTRFBS, which is also used
by banks and bullion dealers. As you are a tech savvy
industry, you won’t want or need paper reports, which is good as
AUSTRAC has commenced phasing out paper report forms. Access to electronic reporting
is via AUSTRAC Online, that is, which you
will have access to once your business is registered. By default, you will have access
to the SMR and TTRFBS data entry forms. There are XML schemas and
file, report file format specifications, and these are
available from AUSTRAC Online if you wish to start to build an
automated reporting system. And while you’re building that
reporting system, you can still meet your obligations by
using the data entry forms. There are two options for
submitting XML documents; manual file upload via AUSTRAC Online
and automated file transmission. Before you start reporting via
XML, and as digital currency exchanges are new to reporting
to AUSTRAC, you must go through a test file process. This allows AUSTRAC to gauge
your understanding of the reporting obligations and to
provide feedback with regards to compliance with reporting. Once AUSTRAC is satisfied
your XML report, with your XML reporting, you will be granted
access to this reporting method in AUSTRAC Online. Test file processes can be
booked through the AUSTRAC contact centre. And so that’s about it for
reporting obligations so I’ll now hand back to Richard, who
will take you through the policy principles.>>Mr Richard Lee: Thanks, Wendy. The policy principles are
designed to help businesses transition to new regulation. The principles were provided to
the AUSTRAC CEO by the Minister for Law Enforcement and Cyber
Security, Angas Taylor, and you can view them on
the AUSTRAC website. They apply for six months, from
3 April 2018 to 2 October 2018 inclusive, giving businesses a
six-month period to become fully compliant with the legislation. During the policy principle
period, AUSTRAC may only take enforcement action if the
digital currency exchange provider has not taken
reasonable steps to comply with the relevant provisions. And in considering whether
digital currency exchange has failed to take reasonable steps
to comply, AUSTRAC must have regard to at least four things:
whether the relevant provisions are complied with as soon as
practicable in respect of a customer who is assessed by the
digital currency exchange to be a high-money laundering or
terrorism-financing risk, any transition plan or other
measures implemented by the digital currency exchange
outlining actions and timeframes to achieve compliance, the
extent of oversight by the digital currency exchange’s
board or CEO of any transition plan or other steps towards
complying with the Act, whether sufficient resources have been
allocated to enable compliance with the Act. AUSTRAC is currently considering
how it will engage with industry during the policy principles
period to gauge progress on meeting the requirements. The policy principles do
not include registration, so providing a designated service
now, while unregistered is a criminal offence. Now, also some important
information on guidance I wanted to quickly discuss. These pieces of guidance cover
in more detail what we have covered today. We have a dedicated page for
digital currency exchanges on our website. This page has links to our
compliance guide, links to enrolment and registration, as
well as a document that will help prepare and implement an
AML/CTF program, which we’ve discussed today. That actual document not only
takes you through the technical requirements and how to address
them, but also gives you some tips on what to look out
for and report to AUSTRAC. Some examples are when a
customer, for example, provides false identification, when
customers interact with the darknet, tumblers and illegal
offshore wagering websites, as well as when a customer
is subject to ransomware. In fact, some exchanges are
actually asking whether or not a transaction relates to
ransomware, asking the customers that when collecting
KYC information. When structuring occurs;
structuring, for those that aren’t aware, involves behaviour
that indicates a customer is deliberately undertaking
transactions to avoid reporting requirements: a series of
transactions below the $10,000 reporting threshold for example. Other examples in the guide are
when the beneficial owners of a customer cannot be identified,
when unusual rapid movement of funds occur and the detection
of unregistered digital currency exchanges. We also have a compliance
insights document, which outlines where reporting
entities are performing well and areas for improvement,
which also will assist. And finally, if you still have
questions, you can contact our information service centre
on the number provided or via email, which is up
there on the screen. And that winds up the
presentation today around digital currency exchanges. And I’ll hand back to Tony.>>Mr Tony Prior:
Thanks, Richard. We’ve certainly covered a
lot of information today. But we still have time for a few
questions, and a couple of those have come through already. I’ll pose these to the panel. The first one
relates to identify. And the question from the
audience is: Do we have to identify every customer, even if
they’re exchanging a very small amount?>>Mr Richard Lee: Yes. There the threshold is zero. So, any exchange of digital
currency to Fiat or traditional currency or the other way around
requires identification to be completed. Now, again, the guide outlines
the steps or what’s required to conduct for KYC purposes of
know your customer purposes, and there’s also a ready reckoner
in the compliance guide as well, which really quite well
sets out what’s required.>>Mr Tony Prior:
Thanks, Richard. Another question: My business is
due to commence operating next week. What do I need to do?>>Ms Wendy Freidman: Well, in
this case, you need to register with AUSTRAC, so get your
application in, and because it’s an offence to provide digital
currency exchange services while being unregistered.>>Mr Tony Prior: Thanks, Wendy. We’ve got a question around
policy principle period: So, will AUSTRAC be undertaking
compliance activities during the policy principle period?>>Mr Richard Lee: I did mention
that we were gauging, we’re looking at, considering what
we’re going to do there. Obviously, someone wants to
know more, but that’s fine. At this stage, there will be
some interactions with industry. There’s a number of
things happening. We’re considering surveys to
understand where you’re at with your obligations, how
you’re meeting them. We may undertake some desk
reviews and onsite assessments as well. It’s also important to note that
yes, we did conduct workshops and a number of
businesses attended those. We intend to get industry back
in the room in the next few months and to hear from them
what they’re experiencing, whether it be as part of their
risk assessment, what they see their risks are, what they’re
doing to monitor their customers, and also what
they’re seeing in reports. Obviously, we don’t go into
specifics of transactions and names and whatnot of, of
customers, but just to share across the industry what we’re
seeing and to try to boost the capability
across the sector.>>Mr Tony Prior: Well, those workshops were very useful.>>Mr Richard Lee: Stay tuned. There will be some interactions
around the policy principles period.>>Mr Tony Prior: A question
around that association with AUSTRAC. The question is: Can we put the
AUSTRAC logo on our website or say we are endorsed, approved
or licensed by AUSTRAC?>>Ms Wendy FREIDMAN: No. As mentioned earlier,
you cannot do that. You can’t make any suggestion
that AUSTRAC or the Commonwealth Government endorses your
business or any products or services that you provide. So please, do not use
our logo on your website.>>Mr Richard Lee: By all means
if you are registered, you can say you’re registered,
because that’s a fact.>>Mr Tony Prior: A question
around politically exposed persons: So how could
a business identify whether a customer is a politically
exposed person or PEP, as they use the term?>>Mr Richard Lee: The compliance
guide does give you some tips there actually. And it mentions things like
publicly available information, threat searches through the
media, social media, that type of thing, consulting reports and
databases, organisations that identify, corruption
risk is another good one. And there’s also online PEP
databases that businesses can subscribe to. So, check out the compliance
guide, because it does have a lot of information around PEPs
and gives you some tips on ways to verify your customers to
see whether they are PEPs.>>Mr Tony Prior:
Thanks, Richard. This question is coming from
someone who is considering, or in the process of registration. So: What are some possible
reasons for AUSTRAC refusing registration?>>Ms Wendy Freidman: Refusal is
based on the suitability and if there are grounds of, sorry. I’ll try and get the
wording correct here. Can be refused on the grounds
of the risk of money laundering, terrorism financing, people
smuggling, or any other serious crime posed by
registering that entity.>>Mr Richard Lee: So, the power
is actually very similar to the power of a registration
of remitters as well. And obviously AUSTRAC’s take
action over the last few years around refusing registration,
cancelling registrations and suspending, so similar grounds,
whether the business operating are providing a designated
service is significant ML/TF risk.>>Ms Wendy Freidman: And apart
from refusing registrations, AUSTRAC also has the power to
cancel or suspend registrations as well. So just be aware of that. And it all goes
back to that risk.>>Mr Richard Lee: Yes, as well
as imposing conditions as well.>>Ms Wendy Freidman: Yes.>>Mr Richard Lee: So, they
can continue to operate under certain conditions.>>Mr Tony Prior: This is a
little similar to a question we had earlier in the
webinar to Dan, but I think it’s worthwhile we revisit it: If we
have a suspicion a customer is involved in money laundering
or terrorist financing or other crime, should we cease
doing business with them?>>Mr Richard Lee: So just to
reiterate, the Act doesn’t require you to. You need to determine, make that
decision based on your ML/TF risk of continuing to
provide that service. Now, if you do continue to
provide that service and more suspicious activity occurs,
you need to continue to report. And the final point I think
we mentioned was the risk of tipping-off. So obviously you wouldn’t tell
your customer, if you do end the relationship, that hey, we’re
ending the relationship because we reported to AUSTRAC. So certainly don’t do that. So, they’re the key points
I think to keep in mind.>>Mr Tony Prior: I know we
touched on this, but there was a question around the exchange or
the register being made public. So: Would the Register of
Digital Currency Exchange Providers be made public?>>Mr Richard Lee: Do
you want to answer that?>>Ms Wendy Freidman: Yes. Not at the moment. But we are considering
it for the future.>>Mr Richard Lee: And in
what form as well, I mean the remitter register is in a
certain form on the website. So, we’re looking at
a number of options. And the first option is
whether we do it and how.>>Mr Tony Prior:
I’ve got a question. I think this has come through
from a reporting entity already who is perhaps
entering into DCE. So, it says: If we start
offering an additional digital currency for our exchange,
do we need to tell AUSTRAC? So, if you like, a new
designated service.>>Ms Wendy Freidman: Well, a
designated service or currency? I think there’s questions
about the currency. No, there’s no need to inform
AUSTRAC when you start or, for that matter, cease trading
in a particular currency. You will be reporting details
of digital currency on your transaction reports, especially
what the customer has transacted in. But as there are new digital
currencies being created every day, there’s no need to tell us
when you start or stop dealing in a particular currency.>>Mr Richard Lee: So, if it
was a new designated service, obviously it would have to be
notified as an enrolment update, something to consider. If a new digital currency is
being offered, look, maybe you should consider your ML/TF risk. Has it affected your ML/TF risk? If it does, well then you need
to update your policies and procedures to mitigate
and manage that risk.>>Mr Tony Prior: I think we’ve
got time for one more: If we only exchange one way – and
they give the example money to digital currency – are we still
captured by the legislation?>>Mr Richard Lee: This question
actually came up in the workshops a few times. Absolutely, you are. So, the wording in the
designated service, which I put on the screen had the
word ‘or’, not ‘and’. So yes, if you are only doing
one-way, yes, you are captured and that is a designated
service and you need to meet the obligations which
we’ve described today.>>Mr Tony Prior: Well that’s
all we’ve got time for today. So, I’d like to thank you all
for attending this webinar. And just another reminder about
the guidance, it’s available on the AUSTRAC website. And if you could take a couple
of minutes to complete the short survey in the tab on your screen
it would be greatly appreciated. That pretty much winds up the
session or the presentation for today. If we’ve got some questions that
come through that we haven’t been able to answer during
the question, we’ll make those available. Okay, thank you to the panel.>>Daniel: Thank you.>>Ms Wendy Freidman:
And thank you.

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