Financial planners and advisers give customers advice on their investment needs (typically for long-term savings and pension provision) and selecting the appropriate products.
Financial planners and advisers, either only give advice or they act on behalf of their customers in dealing with a product provider.
The typical customers of financial planners and advisers are personal clients (including high net worth individuals), trusts and companies.
The Money Laundering and Terrorism Financing (ML/TF) risks associated with financial planners and advisers include:
Criminals may seek to conduct their financial activity through a planner or adviser to disguise their involvement;
Criminals may seek out planners and advisers as gatekeepers to the financial system to give the impression of respectability and legitimacy; and
Criminals may seek the assistance of planners and advisers to obscure who really owns or controls the funds and assets.
Financial planners and adviser must ensure the organisation conducts a comprehensive ML/TF risk assessment to identify, assess, mitigate and manage ML/TF risk exposures as a critical first step in complying with AML/CFT laws.
What are the AML/CFT obligations?
In developing responses to obligations under AML/CFT laws and regulations the following steps must be undertaken:
Conduct a Money Laundering and Terrorism Financing Risk Assessment;
Develop an AML Program that is proportionate to ML/TF Risks;
Establish effective Board and Senior Management oversight of the AML/CFT Program;
Appoint an AML Compliance Officer;
Establish a Customer Due Diligence (CDD) Program including collection and verification of know your customer (KYC) information including Enhanced and Ongoing CDD controls;
Implement an ML/TF Risk Awareness Training Program for staff;
Implement a monitoring program to identify unusual and possibly suspicious customer activity, transactions and behaviour;
Establish a process to report suspicions and other activity specified by AML/CFT law and regulation;
Establish Record-keeping controls; and
Maintain the ML/TF Risk Assessment and the AML Program as the business and risks change.
How can AML Accelerate help?
AML Accelerate, drawing on unparalleled expertise and real-world experience, has developed an AML/CFT Program Manual for financial planners and advisers.
Our solutions deliver all the foundational AML/CFT materials including an ML/TF Risk Assessment, an AML/CFT Program, CDD Standards, and an AML Operating Manual, which you can tailor to your specific needs, ensuring your AML/CFT controls are commensurate with your business.
What is AML Accelerate?
AML Accelerate Pty Ltd is a joint venture between Arctic Intelligence and Initialism to provide solutions, that enable regulated businesses to accelerate their AML compliance efforts at an affordable price regardless of their size, industry sector or geographic location.
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