What is the AUSTRAC Compliance Report?
The annual compliance report is a self-assessment of your anti-money laundering and counter-terrorism financing (AML/CTF) compliance.
It is an opportunity to share with AUSTRAC how you are complying with your AML/CTF obligations and helps them to understand what assistance you might need, and governance changes they can make to facilitate.
AUSTRAC uses the information they receive to:
- Measure the effectiveness of your AML/CTF compliance
- Increase AUSTRAC’s understanding of ML/TF risks across different businesses and industries
- Improve education and guidance
If you are reading this now, you have probably just gone through the process on AUSTRAC Online of filling in the questionnaire and submitting your answers to be compiled into a report. Alternatively, you haven’t ever done a yearly AUSTRAC compliance report and as a new reporting entity looking for some information on how to best prepare for the next one.
We have been in collaboration with ACAMS Australia and The GRC Institute to follow and assist compliance professionals to both understand and implement the changing nature of the compliance report in their respective organisations.
In this post, we will share information on the changes to the compliance report this year and recommend practices which will help you best prepare for the next time you need to report.
The changes to this years AUSTRAC AML/CTF Compliance has been well articulated in an “Insights on AUSTRAC’s updated Compliance Report for 2019” by Lisa Dobbin and Chris Cass from Deloitte’s risk advisory team.
In this article, the authors highlight five key themes AUSTRAC is emphasising by making changes to the yearly compliance reporting procedures. To share one astute point;
“The increasingly quantitative nature of the questions suggests a more formal and data-driven approach is likely to be taken by AUSTRAC in the future when reviewing the Compliance Reports in their supervisory capacity, and starting to demonstrate a pivot in AUSTRAC’s focus towards the extent to which reporting entities are looking at the application of risk intelligence derived from, among other things, their sub-sector risk assessments.”
The team at bronID agree with this statement and will support AUSTRAC’s choice to prioritise taking a more data-driven approach to facilitating the best possible regulatory compliance framework for Australian reporting entities.
AUSTRAC’s enforcement actions against both Tabcorp and CBA highlight the need to improve our AML/CTF risk assessments and procedures. As seen in a recent blog post: A Lesson in AML CTF Governance the Royal Commission into Banking Report
bronID is here to help you comply with AUSTRAC
Let’s have a look at what AUSTRAC Compliance Report Questions came up this year and think about how you can prepare the data-driven quantitative evidence required by AUSTRAC and improve your response next year?
By following our AML Compliance Series, starting with “How to comply with the AML/CTF Act Series - an introduction” you will begin to answer some of the questions required. Here are the question categories mapped to the relevant ‘How to Comply’ post. If you complete these steps while utilising the bronID portal, your answers are recorded and whenever a change is made the relevant data updated.
Managing your program
Independent review of your program
Assessing your ML/TF Risk
Managing your Employee Risk
Managing your Customer risk
Reporting and AUSTRAC feedback
Some essential things to consider which will help you comply with AUSTRAC
- Data management and hygiene.
- Building compliance reporting systems which preserve an individuals privacy, yet are open to being transparent when required.
- Setting triggers to automatically update your AML Program and your compliance policy and procedures to reflect any relevant changes.
“We observe that, outside of legislative changes, many reporting entities have made limited changes to their AML/CTF program in the last 10 years.” Insights on AUSTRAC’s updated Compliance Report for 2019.
- Ongoing Risk Assessment of Customers.
- Customise the policy and procedures to suit your business and products.
- Recognising the cross over between the questions in the compliance report and the question your compliance officer should be addressing every day internally.
How can bronID help?
The bronID identity suite is a platform used to help you formulate and execute on your AML/CTF policies and procedures while aggregating your compliance data in one place.
bronID provides reporting entities with the tools to make both achieving your compliance obligations as well as reporting the relevant and necessary data to AUSTRAC straightforward and convenient. bronID can be your medium to help AUSTRAC take a more data-driven approach to fight financial crime and improve your own AML/CTF compliance procedures.