The end of the 15 month moratorium period for phase 1 of AML implementation ends on 12 March 2009.
The next set of AML obligations commences on 12 December 2008. Phase 2 requires affected organisations to meet reporting obligations, carry out customer due diligence and monitor transactions.
Liz Atkins, Austrac's General Manager Regulatory Policy recently made the following observations about compliance to date:
- Austrac expects reporting entities to have appointed an AML/CTF Compliance Officer;
- in the area of employee due diligence, she reminded businesses that staff needed to be re-screened if they were moved to sensitive areas;
- program reviews needed to be done by someone not involved in the development of the program or operational staff.
According to Austrac's 2007-2008 Annual Report, it received 29,089 suspect transaction reports and 2,934,955 significant cash transactions reports in 2007-2008.
Austrac analyses the reports and passed on suspect transaction notifications to its domestic partner agencies including 27.730 to the ATO, 3072 to the Australian Federal Police and 1468 to the Australian Custome Service.