AUSTRAC has released for consultation draft alternative identification processes reporting entities can use to assist customers who may have difficulty providing standard identification.
The updated guidance would clarify that reporting entities:
- Are not limited to use alternative identification procedures for low-risk customers only. They must assess and take appropriate steps to mitigate and manage the money laundering and terrorism financing (ML/TF) risks associated with accepting alternative identification.
- Can continue to rely on alternative identification when a customer faces systemic and long-term barriers to accessing standard identification.
- Can apply ongoing customer due diligence based on a customer’s overall ML/TF risks, rather than applying a higher level of ongoing customer due diligence solely on the basis that a customer has been identified using alternative procedures.
- Should use reliable and independent documents or data to verify a customer’s identity to reduce ML/TF risk, rather than stating they must do this.
- Can use recently expired identification documents as a form of alternative identification.
Austrac has also published new lists of sector-specific suspicious activity indicators to help identify potential money laundering, terrorism financing and other serious and organised criminal activity.
The indicators are for the following sectors:
Banking
Bookmakers
Bullion dealers
Casinos
Digital currency (cryptocurrency)
Financial planners
Life insurance
Not for profits
Online betting agencies
Pubs and clubs
Remittance service providers
Securities and derivatives
Superannuation
Non-bank lenders and financiers
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Author: David Jacobson
Principal, Bright Corporate Law
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About David Jacobson
The information contained in this article is not legal advice. It is not to be relied upon as a full statement of the law. You should seek professional advice for your specific needs and circumstances before acting or relying on any of the content.
