ARTICLE · 28 AUGUST 2007

Employer Due Diligence Program – Will You Be Ready?

Minter Ellison

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On 7 December 2006, Parliament passed the Anti Money Laundering and Counter Terrorism Financing Act 2006 (AML/CTF Act). To date, there has been little focus on the ‘employer’ obligations of organisations who are covered by the AML/CTF.

AustraliaEmployment and HR

On 7 December 2006, Parliament passed the Anti Money Laundering and Counter Terrorism Financing Act 2006 (AML/CTF Act). To date, there has been little focus on the ‘employer’ obligations of organisations who are covered by the AML/CTF. In many ways, those obligations have been the ‘sleeper’ issue of the AML/CTF Act.

With an employer’s obligation to implement an Employee Due Diligence Program and a Training Program to commence on 12 December 2007, the employee issues must now be a key part of all compliance plans.

Which employers are covered?

The AML/CTF Act is likely to apply to an employer if it undertakes a business in the financial sector or gambling sector, is a bullion dealer or other professional or business that provides particular designated services. Examples of employers covered by the AML/CTF Act include retail and investment banks, money lenders, superannuation funds, life insurance companies, stock brokers, fund managers and financial planners.

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