Consultation on modernising Australia’s AML/CTF regime

In June 2023, AusPayNet responded to the Attorney-General’s Department’s consultation on modernising Australia’s anti-money laundering and counter-terrorism financing (AML/CTF) regime.

The AML/CTF regime is a critical part of Australia’s efforts to prevent criminals from receiving the proceeds of their illegal activity and stopping funds from falling into the hands of terrorist organisations. As observed in the consultation paper, the regime has not kept pace with the changing threat environment and evolving international standards, resulting in gaps and vulnerabilities that could have significant economic and social consequences for Australia.

In line with AusPayNet’s commitment to working with Members, government and other stakeholders to defend the payments system from economic crime, our submission welcomed the review of the AML/CTF regime to ensure that it remains clear, fit-for-purpose and meets international standards and best practice. We expressed support for:

• Simplifying and modernising the AML/CTF regime to help businesses better understand and comply with their obligations, and promote consistency in application across entities.
   
• Amending the tipping-off offence to enable greater collaboration between financial crime teams across the ecosystem, to facilitate the detection and disruption of economic crime.
   
• Expanding the AML/CTF obligations to digital currency exchanges and tranche-two entities, in line with the international Financial Action Task Force (FATF) Standards.
   
• Updating and simplifying the customer due diligence obligations, including to reflect developments in identification technology and processes.
   
• Ensuring that any changes to the travel rule obligations account for the data limitations of Australia’s direct entry system, to ensure that BECS can continue to support the settlement of the significant share of Australia’s payment transactions that it does currently.

AusPayNet’s submission is available below.