With a number of high profile cases and inquests into money
laundering being played out in the media recently, many directors
and Responsible Managers are taking the opportunity to give serious
consideration to how to mitigate similar occurrences in their
business.
A good starting point is the existing guidance and commentary.
Australian Transaction Reports and Analysis Centre
("AUSTRAC") has previously released a
report on governance, including key insights developed by AUSTRAC
in the course of its regulatory activities. The report is designed
to assist reporting entities to understand the expectations AUSTRAC
has in relation to governance. In the report, AUSTRAC notes that
governance "involves more than just having AML/CTF as a
standing item for mention at meetings". They go on to
note that all personnel should be aware of the various risks
impacting the business and the systems and controls implemented to
address these risks.
