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Industry Consultations

Presented at the Financial Action Task Force (FATF) FinTech/RegTech Forum in San Jose

How RegTech can support the AML/CTF Supervision Regime – Presented at FATF RegTech/FinTech Forum in San Jose – 25/05/17 – Neil Jeans – Co-Founder, AML Accelerate

On the 25th and 26th May, as a co-founder of AML Accelerate www.amlaccelerate.com and through the international recognition the RegTech Association has received since launching, Neil Jeans attended the FATF FinTech/RegTech Forum at PayPal’s Head Quarters in San Jose, California.

The Forum brought together the public and private sector to collaboratively discuss the AML/CFT reality and challenges within the FinTech and RegTech sectors.  Outreach to the FinTech and RegTech community is one of the FATF’s priorities for 2016-2017.

At this forum a paper was presented called How RegTech can support the AML/CTF Supervision Regime to an audience comprised of numerous AML Supervisors from around the world.

This paper has since been presented and shared with regulators in Australia, New Zealand, Indonesia, Malaysia, Qatar and Singapore, as we continue to engage in dialogue around how technology can help them to effectively regulate a growing number of new businesses in response to this expectation set out by the Financial Action Task Force (FATF).

Read full submission…

For more information on the FATF FinTech/RegTech Forum visit the Financial Action Task Force (FATF) website – click here.

Hong Kong AML/CFT regulatory reform consultation

Response to consultations on enhancing the Anti-Money Laundering Regulation of Designated Non-Financial Businesses and Professions – 07/03/17 – Neil Jeans – Co-Founder, AML Accelerate

We would like to thank the Financial Services and the Treasury Bureau (FSTB) for the opportunity to provide input into this important consultation.

The inclusion of DNFBPs into AML/CFT regimes is long overdue.  It can also be argued that the non-inclusion of DNFBPs from AML/CFT regimes places a disproportionate burden on current businesses subject to AML/CFT law and regulation.

The non-inclusion of DNFBPs also hampers a country’s ability to put in place a comprehensive, proportionate and effective AML/CFT regime based on all money laundering and terrorist financing risks, as required by the FATF. 

We appreciate that regulation of this kind will be alien to many types of DNFBP, and that some DNFBP sectors will resist AML/CFT regulation despite clear and unequivocal evidence of their industry playing a role in money laundering and terrorist financing. 

It is our experience that the same arguments were raised by DNFBPs in other jurisdictions when they were brought into the AML/CFT regime.  However, once part of the AML/CFT regime, organisations realise the benefits to their business and its reputation as well as to society in general.

Read full submission…

New Zealand draft amendment bill for Phase 2 AML/CFT Act

Response to the New Zealand Ministry of Justice in response to industry consultation on the draft amendment Bill regarding the Phase 2 AML/CFT Reforms – 25/01/17 – Neil Jeans – Co-Founder, AML Accelerate

We would like to thank the Ministry of Justice for the opportunity to provide input into these important consultations on the draft amendment Bill regarding the Phase 2 AML/CFT Reforms.

The inclusion of DNFBPs into AML/CFT regimes is therefore long overdue.  It can also be argued that the non-inclusion of DNFBPs from AML/CFT regimes places a disproportionate burden on current businesses subject to AML/CFT law and regulation.

The non-inclusion of DNFBPs also hampers a country’s ability to put in place a comprehensive, proportionate and effective AML/CFT regime based on all money laundering and terrorist financing risks, as required by the FATF. 

We appreciate that regulation of this kind will be alien to many types of DNFBP, and that some DNFBP sectors will resist AML/CFT regulation despite clear and unequivocal evidence of their industry playing a role in money laundering and terrorist financing. 

It is our experience that the same arguments were raised by some of the businesses included in Phase 1 and by DNFBPs in other jurisdictions when they were brought into the AML/CFT regime.  However, once part of the AML/CFT regime, organisations realise the benefits to their business and its reputation as well as to society in general.  

Read full submission…

Industry consultation on a model for regulation under Australia’s anti-money laundering and counter-terrorism financing regime

Response to the Attorney General’s Department in response to industry consultations on a model for regulation under Australia’s anti-money laundering and counter-terrorism financing regime – 30/01/17 – Neil Jeans – Co-Founder, AML Accelerate

We would like to thank the Attorney General’s Department for the opportunity to provide input into these important consultations on the model for regulation of DNFBPs.

The inclusion of DNFBPs into AML/CFT regimes is long overdue.  It can also be argued that the non-inclusion of DNFBPs from AML/CFT regimes places a disproportionate burden on current businesses subject to AML/CFT law and regulation.

The non-inclusion of DNFBPs also hampers a country’s ability to put in place a comprehensive, proportionate and effective AML/CFT regime based on all money laundering and terrorist financing risks, as required by the FATF. 

We appreciate that regulation of this kind will be alien to many types of DNFBP, and that some DNFBP sectors will resist AML/CFT regulation despite clear and unequivocal evidence of their industry playing a role in money laundering and terrorist financing. 

It is our experience that the same arguments were raised by some of the businesses included in Tranche 1 and by DNFBPs in other jurisdictions when they were brought into the AML/CFT regime.  However, once part of the AML/CFT regime, organisations realise the benefits to their business and its reputation as well as to society in general.

Ours is a consolidated response covering all five consultation papers on the model for regulation under Australia’s AML/CTF regime, namely:

  • Accountants
  • High Value Dealers
  • Legal Practitioners and Conveyancers
  • Real Estate Professionals, and
  • Trust and Company Service Providers

AML Accelerate was established to provide automated cost effective solutions to support reporting entities’ compliance with AML/CTF obligations, and  has recently developed a solution for reporting entities that allows them to on-line undertake a ML/TF risk assessment and develop an AML/CTF program (including customer due diligence standards) that is compliant with AML/CTF requirements.

Read full submission…