“Suspicion” is such a low threshold to reach yet we find that AML Compliance Officers and their operations staff often try to play detective to solve the case. It’s important to understand that the decision to submit a Suspicious Matter Report to AUSTRAC is based only on the information to which you have reasonable access. One of those sources should be some fairly simple internet searches to determine if your organisation is doing business with a convicted felon. Then it’s up to senior management to ensure smart decisions are taken with regards to continuing to do business with those individuals.
Regardless of your decision to submit, or not submit an SMR, be sure that you document the reasons behind that decision.
As an AML Compliance Officer you will continually be battling with the conflict of revenue raising versus compliance. Your strength and integrity will be tested. Will your decisions result in a 60 Minutes expose like this one with Crown Casino?
This 60 Minutes interview with CEO Todd Harland highlights the fundamentals of an AML regime and when it isn’t effectively managed the ability for organised crime to operate flourishes.