Luke Raven

🌎 A Quick Trip Around the Globe for Updates in AML and Financial Crime 1️⃣ N26 Bank fined 9.2 million euros by German regulator 2️⃣ U.S. Treasury considers further regulations to curb money laundering 3️⃣ Labour outlines crackdown on kleptocracy 4️⃣ Australia passes digital ID laws 5️⃣ U.S. arrests 2 Chinese nationals in crypto scam 🔷Sanctions: 1️⃣ EU set to sanction 10 new individuals and entities linked to Iran 2️⃣ Biden administration supports sanctions against ICC officials 3️⃣ China sanctions 12 U.S. military companies and 10 executives 🔷Corruption: 1️⃣ Former Malaysia PM denies involvement in corrupt practices 2️⃣ Russia detains high-ranking official for bribe-taking 🔷Gaming and Gambling: 1️⃣ SkyCity Casino operator accepts AUS$67 million fine #financialcrime #aml #sanctions #corruption #kyc #regulatoryupdates #amlcompliance #crypto #gaming

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Changes in Australia's AML/CTF Regulations Impacting Digital Currency Services - https://lnkd.in/dyCKsGVK Australia's Attorney-General's Department (Department) has released five consultation papers outlining proposals for broad reforms to Australia's anti-money laundering and counter-terrorism financing (AML/CTF) regime. This publication (the second

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ADDISONS UPDATE | Australian AML / CTF Tranche 2 regime reforms Following on from the first round of consultation conducted last year, AUSTRAC has published a series of proposals in respect of reform to the AML/CTF regime in Australia. This includes a general reform overview as well as reform proposals for the introduction of specific requirements applicable to real estate professionals, professional service providers, dealers in precious metals and stones, digital currency exchange providers and remittance service providers (that will be tranche 2 of Australia’s AML/CTF regime) and broader reforms to simplify/modernise the regime. AUSTRAC has now opened another round of consultation on the reform proposals and is seeking input from all stakeholders, including current and proposed new reporting entities. The consultation period will be open until 13 June 2024. The tranche 2 reforms will ultimately broaden the reach of the AML/CTF regime into new sectors and business activities. Will the reforms incorporate you or your business? Do you understand the nature of the proposed obligations and compliance expectations of AUSTRAC? The landing page for the consultation can be accessed here: https://hubs.li/Q02v-q0P0 For further information regarding the reform proposals or consultation, please contact Addisons partner Jamie Nettleton or special counsel Lachlan Gepp.

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Is your AML/CTF transaction monitoring program really identifying money laundering methods? One of the continuing themes from the AUSTRAC CEO's speech at the ACAMS Conference is that many organisation's are not getting transaction monitoring right. 'Set and forget' programs are not responding to evolving money laundering methodologies, raising a risk of criminal exploitation. AUSTRAC officers have repeated this message through several forums, thus tolerance of non-compliance will be low. Another theme in the speech that will be of no surprise to AML/CTF practitioners is that real estate is a highly desirable means to transfer and store wealth from illegitimate sources. This will be part of the national money laundering/terrorism financing risk assessment that will come out in July. Stay tuned. Read the full speech here - https://lnkd.in/gMF4pwZx #amlcompliance #australia #transactionmonitoring #realestate #amlctf

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AUSTRAC has released its National Risk Assessment for AML/CTF in Australia. Key excerpts include: "Crimes generating the highest value of illicit proceeds that require laundering are assessed to be drug offences,... tax and revenue crimes, as well as defrauding government-funded programs." "Criminals continue to use established channels such as cash, luxury goods, real estate, domestic banks, casinos and remitters to launder funds in Australia." "Opaque legal structures can be created in Australia and used by criminals to help conceal their identity and illicit activity..." "The use of professional service providers, either witting or unwitting, to establish, advise on or operate corporate and financial infrastructure also reduces visibility of the ultimate beneficial owner and creates money laundering vulnerabilities for Australian authorities and industry." https://hubs.la/Q02FXHn70

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Update | Australian AML / CTF Tranche 2 regime reforms Following on from the first round of consultation conducted last year, AUSTRAC has published a series of proposals in respect of reform to the AML/CTF regime in Australia. This includes a general reform overview as well as reform proposals for the introduction of specific requirements applicable to real estate professionals, professional service providers, dealers in precious metals and stones, digital currency exchange providers and remittance service providers (that will be tranche 2 of Australia’s AML/CTF regime) and broader reforms to simplify/modernise the regime. AUSTRAC has now opened another round of consultation on the reform proposals and is seeking input from all stakeholders, including current and proposed new reporting entities. The consultation period will be open until 13 June 2024. The tranche 2 reforms will ultimately broaden the reach of the AML/CTF regime into new sectors and business activities. Will the reforms incorporate you or your business? Do you understand the nature of the proposed obligations and compliance expectations of AUSTRAC? The landing page for the consultation can be accessed here: https://hubs.li/Q02v-NHk0 For further information regarding the reform proposals or consultation, please contact Addisons partner Jamie Nettleton or special counsel Lachlan Gepp. #addisons #investedinclientsuccess #aml

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The new financial crime guide was developed in response to an increasing trend for foreign students to be used as money mules. AUSTRAC https://lnkd.in/dxX9TJWt

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Mid-Year AUSTRAC Priority Reminder: Reporting Meeting your reporting obligations is a critical component of AML/CTF compliance. Timeliness is paramount, businesses must ensure that all required reports; International Funds Transfer Instructions (IFTIs), Threshold Transaction Reports (TTRs), and Suspicious Matter Reports (SMRs) are submitted within their respective deadlines. This involves establishing robust internal processes to gather, verify, and report data promptly. Businesses must implement checks and balances to ensure that all reported information is precise and comprehensive. Training staff on the importance of accurate reporting and the specifics of AUSTRAC's requirements can help maintain high standards. If you have any questions or need advice when it comes to your reporting obligations, please reach out. #AML #Reporting #AUSTRAC #Automation

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AUSTRAC continue to be one of the best & most communicative regulators by issuing MONEY MULES GUIDANCE! Mules are taking Australia by storm. It's by no means a new typology... I think I've been dealing with mules in one form or another since the beginning of my #financialcrime fighting career. The reason they're SO prolific these days is that mules are a cheap and easy method when funds come from being stolen or defrauded and need to go somewhere via transfer, whether directly or otherwise, from a victim account. This crime type 📈 = number of mule accounts 📈 The report is quite good, albeit nothing really new... - Money Mules are often international students recruited for access to their bank accounts; - This is only outnumbered, in my experience, by those who apply for a "job scam" to be an account administrator (or whatever) and move money for others through their own bank accounts. The reason Mules are so great for a bad guy is twofold: 1) when the cops come knocking, they find a poor unfortunate victim in their own right, or an international student who has long since flown the coop to go home; 2) when a mule is interacting with bank staff or tech, they don't give off any of the "old school" risk signals since their activity, device and indeed actual face are known and trusted. No "sus IP address" easy wins here 🚨 (BioCatch & GBG Plc can help here - and this is not a sponsored post. I just love these vendors' capabilities on this crunchy problem.) Back to my fave new report though... The thing I like MOST about this guidance is it's return to commonsense use of the word "mule." With a data breach seemingly every other week, criminals have started cutting out the "middle mule" so to speak and signing up for their own drop accounts in others' names. (Again, not new... stolen ID's have been used to establish drop accounts and other tools, like companies, for a VERY long time.) But with this becoming more and more prolific in Australia (thanks largely to AML laws which only require banks to be "reasonably satisfied" that a user is the person they claim to be), many have taken roping this broader category into the term "mule" as well. They are wrong 💁‍♂️ A MULE in the animal kingdom carries others' loads through tricky and dangerous terrain, which is why it's a great metaphor for those helping criminals' transfer their ill-gotten gains through the financial sector... This requires participation, as opposed to victims of ID theft who aren't involved. This leads to another important distinction: true mules are essentially amateur money launderers. Sure, sometimes they're tricked or coerced or unwitting, but let me tell you firsthand: many are willing accomplices & some are straight-up into it 😠 That's why reports like these, and the recent Australian Federal Police education campaign on Aussie uni campuses, are SO great 🎉 They spread the word: DON'T BE A MULE. After all, nobody likes a criminal dumb "ass" 🐴

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💰 Suspicious Matter Reports (SMRs) help the Australian Transaction Reports and Analysis Centre (#AUSTRAC) detect and combat illegal financial activity like #terrorismfinancing, #moneylaundering, and other #financialcrimes. AUSTRAC requires regulated enterprises operating in #Australia, such as financial institutions, money transfer businesses, and casinos, to report any suspicious activity or transactions.🕵🏼‍♀️ Read on to learn more.👇🏼 https://buff.ly/3uXHAbS

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Following the billion-dollar money laundering scandal in Singapore, MAS released their updated Money Laundering National Risk Assessment (ML NRA), which highlights the interconnectedness of global typologies that are increasingly exploiting the nation’s advanced financial system to launder illicit funds. Key takeaways: ❗Identified key areas of concerns that drive ML in Singapore include fraud and scams, organised crime, corruption and tax crimes, and trade-based ML ❗Banking and wealth management institutions pose the highest risk due to high transaction volume, and corporate service providers are the most vulnerable among designated non-financial businesses and professionals (DNFBPs) ❗FIs and DNFBPs need to leverage the right data and technology to stay ahead of evolving threats Read more: https://lnkd.in/e47eGwSx For more information on how your organisation can ensure a robust AML environment, speak with our experts: Prasanna Venkatesan, Brandon Lobo

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The Australian Government is intensifying efforts to combat financial crime, launching the second phase of consultations on proposed reforms to the country's anti-money laundering and counter-terrorism financing (AML/CTF) regime. These reforms aim to align with international standards set by the Financial Action Task Force and target gaps in regulation, particularly in sectors vulnerable to exploitation by criminal networks. https://hubs.la/Q02wM7200

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Gaming and wagering operators, do you know the transaction threshold changes? Have you verified your pre-commencement customers? With Australia's anti-money laundering (AML) and counter-terrorism financing (CTF) regulations tightening, you need to verify pre-commencement customer identities and be on top of changes to transaction thresholds to protect your business from financial crime. Why work with us? ➡️ Accurate verification with global data sources ➡️ Fast, user-friendly onboarding ➡️ Automated compliance processes ➡️ Enhanced security and risk management Learn how to simplify your compliance processes: https://lnkd.in/dAqzv5N4 #AML #CTF #Compliance #Identityverification #Customerduediligence #Customeronboarding

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Gaming and wagering operators, do you know the transaction threshold changes? Have you verified your pre-commencement customers? With Australia's anti-money laundering (AML) and counter-terrorism financing (CTF) regulations tightening, you need to verify pre-commencement customer identities and be on top of changes to transaction thresholds to protect your business from financial crime. Why work with us? Accurate verification with global data sources Fast, user-friendly onboarding Automated compliance processes Enhanced security and risk management Learn how to simplify your compliance processes: https://lnkd.in/dAqzv5N4 #AML #CTF #Compliance #Identityverification #Customerduediligence #Customeronboarding

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In 2023, the Australian Government published two Consultation Papers and a draft bill which, if implemented, will result in significant changes to the licensing and regulation of payment service providers (PSPs) in Australia. (See: https://lnkd.in/gT-_K5RD and https://lnkd.in/grjGpaDh.) Some key proposals : - Requiring a greater proportion of PSPs to hold an Australian Financial Services License (AFSL). Some PSPs which were previously not required to hold an AFSL - e.g. certain remittance service providers relying on pre-existing exemptions - would, under the proposals, likely be captured. - Payment functions to be listed and covered by separate AFSL authorisations. - The intention is to capture service providers which enable cross-border payments into and out of Australia. -  Requiring major stored value facility (“SVF”) issuers holding in excess of $100 million to be authorised by the Australian Prudential Regulatory (APRA). The above proposals largely mirror overseas developments (including in the UK and EU), where the regulatory perimeter for PSPs has been gradually expanding. Gen Advisory’s experienced ex-APRA regulators Michael Lukman and Clement Fernandez are currently helping several PSPs in Australia navigate the above regulatory proposals. Michael and Clement have also previously successfully helped several PSPs apply for and obtain AFSLs. If you’re a PSP wishing to understand the implications of the above regulatory proposals for your business, including whether your business needs an AFSL, please email michael.lukman@gnad.com.au and clement.fernandez@gnad.com.au. #PSPs #PaymentsLicensing #AFSL Gen Advisory Pty Ltd

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The ATO-led Serious Financial Crime Taskforce (SFCT) is warning businesses against using illegal financial arrangements such as false invoicing to avoid tax obligations and/or inflate their deductions. The SFCT is a multi-agency taskforce which combats financial crimes like tax evasion and fraud.  Read more here https://lnkd.in/gRWburE7 #fraud #ATO #moneylaundering

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We have a strong anti-money laundering and counter-terrorism financing (AML/CTF) framework in Australia, however the criminal environment is always evolving. What are the new and emerging money laundering and terrorism financing threats and vulnerabilities Australia faces? How can law enforcement, government agencies and industry contribute to disrupting these crimes? Today we released two new comprehensive national risk assessments to help answer these questions. We encourage businesses to read these assessments, understand the risks they may face and identify ways to mitigate them. Find out more: https://lnkd.in/gPZMHHUe Brendan Thomas #amlctf #nationalriskassessment #fatf #moneylaundering #terrorismfinancing

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