Anti-Money Laundering and Counter-Terrorism Financing Amendment Bill 2024 [Provisions]

Submission 1
 Anti-Money Laundering and Counter-Terrorism Financing Amendment Bill 2024 [Provisions]
Submission 1

Contents
Introduction ................................................................................................................................................................ 3
Overview of the Bill .................................................................................................................................................... 3
Overview of Australia’s AML/CTF regime ................................................................................................................... 3
Rationale for reform ................................................................................................................................................... 4
Money laundering is a significant and growing threat to Australians.................................................................... 4
Regulatory gaps are allowing criminal exploitation ............................................................................................... 5
The existing regulatory framework is complex ...................................................................................................... 8
Australia is not meeting its international obligations ............................................................................................ 9
Responding to other reviews of the regime .........................................................................................................11
Development and consultation on the Bill ...............................................................................................................12
Impact on Industry ...................................................................................................................................................13
Impact Analysis .....................................................................................................................................................13
Deferred commencement ....................................................................................................................................14
Next steps .................................................................................................................................................................15
AML/CTF Rules......................................................................................................................................................15
AUSTRAC guidance and education .......................................................................................................................15
FATF 2026-27 Mutual Evaluation .........................................................................................................................15

2
 Anti-Money Laundering and Counter-Terrorism Financing Amendment Bill 2024 [Provisions]
Submission 1

Introduction
The Attorney-General’s Department (the department) welcomes the opportunity to make a submission to the
Senate Legal and Constitutional Affairs Legislation Committee (the Committee) on the Anti-Money
Laundering and Counter-Terrorism Financing Amendment Bill 2024 (the Bill). This submission provides further
detail to assist the Committee’s consideration and should be read alongside the Bill and its explanatory
materials.

Overview of the Bill

The Bill would amend the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act)
to improve Australia’s ability to deter, detect and disrupt money laundering and terrorism financing. The
reforms in the Bill would also align Australia with international standards set by the Financial Action Task
Force (FATF), the global financial crime stand setter and watchdog.

The three key objectives of the Bill are to:

• expand the AML/CTF regime to certain high-risk services provided by lawyers, accountants, trust and
company service providers, real estate professionals, and dealers in precious metals and stones—also
known as ‘tranche two’ entities
• improve the effectiveness of the AML/CTF regime by making it simpler and clearer for businesses to
comply with their obligations, and
• modernise the regime to reflect changing business structures, technologies and illicit financing
methodologies.

Overview of Australia’s AML/CTF regime

The AML/CTF Act and the Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument (No. 1)
2007 (the Rules) form the basis for Australia’s AML/CTF regime. The AML/CTF Act takes a risk-based approach
to regulation and sets out general principles and obligations for reporting entities to apply to their
businesses. Details of how these obligations are to be carried out are set out in the Rules.

AUSTRAC also publishes a range of guidance materials to assist reporting entities to meet these AML/CTF
obligations. In addition to this regulatory guidance, AUSTRAC develops sector-specific intelligence guidance,
including risk assessments, typology reports and financial crime guides, which provide reporting entities with
information on indicators of criminal activities.

The AML/CTF Act, AML/CTF Rules and guidance (collectively the AML/CTF regime) serve two purposes:

1) “Target hardening” – supporting businesses to understand their risks and take appropriate action,
thereby reducing opportunities for money laundering and terrorism financing to occur, and
2) Financial intelligence – providing law enforcement and national security agencies with the financial
intelligence they require to detect, investigate and prosecute criminal activity, as well as restrain and
confiscate the proceeds, instruments and benefits of crime.

3
Anti-Money Laundering and Counter-Terrorism Financing Amendment Bill 2024 [Provisions]
Submission 1
Anti-Money Laundering and Counter-Terrorism Financing Amendment Bill 2024 [Provisions]
Submission 1
Anti-Money Laundering and Counter-Terrorism Financing Amendment Bill 2024 [Provisions]
Submission 1
Anti-Money Laundering and Counter-Terrorism Financing Amendment Bill 2024 [Provisions]
Submission 1
 Anti-Money Laundering and Counter-Terrorism Financing Amendment Bill 2024 [Provisions]
Submission 1
Virtual asset services

Virtual asset services are a key vector for illicit financing, and AML/CTF regulation has not kept pace with the
increasing uptake and evolving exploitation of these services, or with international standards. The increasing
threat of virtual assets was identified in AUSTRAC’s NRA, which assessed the use of digital currencies to
transfer value as posing a high and increasing threat of money laundering. Virtual assets, such as digital
currencies, allow criminal groups to move funds across borders quickly, cheaply and pseudo-anonymously.

For example, under a Western Australian Police investigation, a criminal syndicate was found to have utilised
a registered digital currency exchange to provide the syndicate with digital currency in exchange for cash,
which was identified as being proceeds of crime. Intelligence gathered during the operation identified much
of the digital currency was stored in wallets that could be accessed off shore.

The FATF has also identified the use of virtual assets as posing a high illicit financing risk. In October 2018,
FATF Recommendation 15 was amended to require countries to apply AML/CTF regulation to the virtual
asset-related services (referred to as ‘limbs’ of the definition of ‘Virtual Asset Service Provider’) identified as
being high risk of facilitating illicit financing activity:

• exchanges between virtual assets and fiat currencies (first limb)

• exchanges between one or more other forms of virtual assets (second limb)
• transfers of virtual assets on behalf of a customer (third limb)
• safekeeping or administration of virtual assets (fourth limb), and
• participation in and provision of financial services related to an issuer’s offer and/or sale of a virtual
asset (fifth limb).

AML/CTF regulation of digital currencies is currently limited to exchanges between virtual currency to fiat
currency (and vice versa) transactions (i.e. the first limb). This means that where criminal groups transfer
value between virtual currencies without a cash-out mechanism on either side of the transaction, there is no
obligation for businesses to implement measures to identify, assess, mitigate and manage the financial crime
risk. Due to this lack of reporting obligations, AUSTRAC and law enforcement’s visibility of the transfer is
inhibited.

Bringing the additional services in the FATF’s definition of ‘Virtual Asset Service Provider’ (specifically, the
second to fifth limbs) within the scope of AML/CTF regulation will close a significant regulatory gap, and
ensure the AML/CTF Act remains up-to-date and robust against potential exploitation by criminals in this
rapidly growing sector.

The existing regulatory framework is complex

The regime is widely considered to be unduly complex and poorly understood, leading to poor AML/CTF
prevention practices and lower quality financial intelligence. The existing regime spans over 700 pages of
legislation, plus published AUSTRAC guidance. The existing regime sets out detailed and prescriptive
procedural requirements rather than setting a clear outcome of the regime to mitigate the risk of serious
financial crimes. Operational experience and stakeholder consultation have highlighted systemic problems
that are largely attributed to this complexity.

8
 Anti-Money Laundering and Counter-Terrorism Financing Amendment Bill 2024 [Provisions]
Submission 1
Key requirements relating to AML/CTF programs and Customer Due Diligence (CDD) are dispersed throughout
the AML/CTF Act and the Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007
(the Rules), making them difficult to follow and creating implementation challenges. A key objective
underpinning the reforms is ensuring a reporting entity’s obligations are clear, easy to understand and reflect
contemporary business practices.

The 2016 Statutory Review of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 and
Associated Rules and Regulations (the Statutory Review) noted the complexity of the current AML/CTF
requirements generates uncertainty and ambiguity for reporting entities.

In particular, the Statutory Review notes that some elements of the AML/CTF regime focused too much on
detailed procedural requirements that make compliance a tick-box exercise, rather than providing a
framework for businesses to protect themselves by mitigating money laundering and terrorism financing
risks. As a result, the current regime does not easily allow entities to adapt and scale their mitigation efforts
and resources to the level of risk they face or the nature of their business.

The Bill would amend many core AML/CTF obligations to help reduce the compliance burden for businesses,
help reporting entities understand their outcomes and obligations, and provide flexibility in how they achieve
their obligations. The key changes are to:

• AML/CTF program requirements – These will be streamlined into high-level obligations that a
reporting entity must meet. The reforms will seek to reduce the regulatory burden on industry by
broadening the scope of group AML/CTF compliance to allow franchised entities, partnerships and
other business structures to combine and fulfil their AML/CTF obligations at a group level. They will
also allow for improved AML/CTF governance within reporting entities by focusing Board
responsibilities on strategic oversight for financial crime risk.
• Customer due diligence – The reforms will allow greater flexibility as to how businesses meet their
risk-based regulatory obligations, and move away from prescriptive identification and verification
requirements that are focused on procedure.

The Bill would also repeal the Financial Transaction Reports Act 1988 (FTR Act) to establish a single source of
obligations for industry (including the transition of solicitors) under the AML/CTF Act. The Statutory Review
noted the significant duplication and regulatory inefficiencies between the FTR Act and the AML/CTF Act.
Repealing the FTR Act would also ensure a more efficient use of AUSTRAC resources.

An added benefit of simplifying and clarifying obligations is that it allows reporting entities to focus efforts on
providing valuable and higher quality information to AUSTRAC, rather than trying to interpret complex
regulation. This in turn allows AUSTRAC to use that information to identify financial transactions linked to
crimes, and improves law enforcement and national security investigations and outcomes.

Australia is not meeting its international obligations

The FATF is an intergovernmental body established in 1989 to protect the global economy from the threats of
money laundering, terrorism financing and proliferation financing. Thirty-nine governments, including
Australia and all G20 countries, are members of the FATF. In addition, the FATF Global Network comprises the
FATF and nine FATF-style Regional Bodies, bringing together more than 200 governments and 20 observer

9
 Anti-Money Laundering and Counter-Terrorism Financing Amendment Bill 2024 [Provisions]
Submission 1
international organisations. Australia is a member and permanent co-chair of the Asia-Pacific Group on
Money Laundering, the FATF-style body for the Asia-Pacific region.

The FATF sets global standards for combatting financial crime, and promotes compliance and effective
implementation of the standards through peer assessment mechanisms—known as mutual evaluations—and
public listing of jurisdictions found to have weak AML/CTF systems.

As a founding member of the FATF, Australia is committed to upholding its standards. Australia also plays an
important global leadership role—including in the Asia-Pacific Group on Money Laundering—to support
countries in our region to strengthen their AML/CTF systems.

The reforms aim to bring Australia into line with global best practice and improve compliance with the FATF
standards in key areas where it is currently rated ‘non-compliant’ (regulation of tranche two entities) or
‘partially compliant’ (regulation of virtual asset services and value transfer transparency).

In addition, the reforms will also improve Australia’s compliance with FATF standards by:

• clarifying risk assessment requirements

• aligning with the FATF principles for foreign branches and subsidiaries
• clarifying the availability of simplified CDD where the money laundering or terrorism financing risk of
the customer is low
• better aligning the requirements for politically exposed persons in the AML/CTF Act and AML/CTF
Rules with international standards
• updating the CDD exemption for gambling services to align with FATF’s threshold, and
• enhancing the transparency of value transfers involving virtual assets.

Potential grey listing

The reforms aim to reduce the risk of Australia being ‘grey listed’ for its long-standing and heavily criticised
inaction on tranche two regulation. Australia’s most recent mutual evaluation was adopted by the FATF in
2015, at which point Australia was found non-compliant or only partially compliant with 16 FATF
recommendations. While there have been some improvements to Australia’s AML/CTF regime since that
time, the FATF membership continues to call out Australia’s non-compliance.

The requirement to regulate tranche two entities has been part of the FATF standards since 2003. The FATF
has repeatedly criticised Australia for failing to regulate tranche two entities in any way. Australia is now one
of only five countries out of over 200 jurisdictions that is completely non-compliant, with some of the
remaining countries initiating reform processes.

As recently as July 2024, Australia’s failure to regulate tranche two entities was highlighted by the FATF 15,
with Australia ranked last for compliance among FATF members. The FATF called on Australia to ‘urgently
ensure that gatekeepers are adequately covered in line with the FATF’s longstanding Recommendations in
this area’.

15
https://www.fatf-gafi.org/en/publications/Fatfgeneral/Gatekeeper-TC-Corruption.html
10
 Anti-Money Laundering and Counter-Terrorism Financing Amendment Bill 2024 [Provisions]
Submission 1
This risk is heightened in the next round of mutual evaluations, as the process for follow-up reporting and by
which countries can be directly referred to the grey list is changing. If Australia has not implemented FATF-
compliant regulation of tranche two entities by the next mutual evaluation, the deficiency will be highlighted
as a key recommended action that Australia must address.

Australia is at high risk of ‘grey listing’ without these reforms. A lack of tranche two regulation, combined
with the results against other FATF standards, may tip Australia into consideration for ‘grey listing’. Members
may directly nominate Australia based on the following:

• inaction for over 10 years from Australia’s 2015 Mutual Evaluation Report that identified tranche two
regulation as a major deficiency
• the gap in regulation being perceived as a risk to the global financial system, and
• an absence of political will due to Australia first committing to implement tranche two regulation in
2003, in line with the FATF Methodology.

Australia’s next mutual evaluation will be in 2026, and substantial effort is required to avoid the negative
consequences of a poor result. Impacts on Australia could include:

• economic impacts and decreased GDP based on reduced incoming capital flows, increased business
costs and potential loss of correspondent banking relationships, due to other countries considering
Australia a risk for financial crime and imposing enhanced due diligence requirements when doing
business with Australia
• increased threat of criminals seeking to exploit perceived weaknesses in Australia’s system and
engage in illicit financial activity—leading to an increased burden on law enforcement
• reduced influence and credibility as a regional AML/CTF leader assisting countries in Australia’s
neighbourhood to combat money laundering or terrorism financing threats, including through
Australia’s central role at the Asia-Pacific Group on Money Laundering, and
• damage to Australia’s international standing, reputation and influence by becoming one of only a very
small number of advanced economies to have ever been grey-listed by the FATF.

By addressing Australia’s deficiencies in tranche two regulation and improving FATF compliance, the Bill will
send a strong message that Australia’s AML/CTF system is integrated and protected to bolster trust in
Australian reporting entities and to make it easier for them to conduct business. If the Bill is not passed, the
AML/CTF regime will become less and less effective, and fall further behind as international standards
continue to develop and strengthen to align with new and emerging risks.

Responding to other reviews of the regime

The Bill also implements recommendations made in the Statutory Review and recommendations from the
Senate Legal and Constitutional Affairs References Committee’s 2022 Inquiry into the adequacy and efficacy
of Australia’s AML/CTF regime (the 2022 Senate Inquiry).

On 20 April 2023, the Government accepted all recommendations of the 2022 Senate Inquiry. The key
recommendation was for the Commonwealth Government to accelerate consultation with stakeholders on
the timely implementation of tranche two reforms in line with FATF recommendations.

11
 Anti-Money Laundering and Counter-Terrorism Financing Amendment Bill 2024 [Provisions]
Submission 1

Development and consultation on the Bill

At its core, the AML/CTF regime is a partnership between the Australian Government and industry.
Businesses play a vital role in effectively detecting and preventing misuse of their sectors and products by
criminals seeking to launder money and fund terrorism.

The department engaged in two extensive rounds of consultation with affected sectors between April 2023
and June 2024. The department received over 270 submissions and conducted over 100 stakeholder
meetings, including industry roundtables, presentation at industry events, and extensive bilateral meetings.

The department also engaged closely with government stakeholders, including law enforcement, national
security agencies, Commonwealth agencies and state and territory regulators.

The department carefully considered all feedback and insights received from the entire consultation process
to inform the development of the Bill, and made tangible amendments to the measures following stakeholder
feedback, particularly on the design and coverage of designated services. The department worked closely
with stakeholders to minimise the regulatory impact of the measures in the Bill, while addressing money
laundering, terrorism financing and proliferation financing risks.

For example, the real estate sector raised strong opposition to the regulation of leasing and auctioneer
services during the first round of consultation in 2023. The department carefully considered all stakeholder
feedback, the money laundering and terrorism financing risk of the proposed designated services,
international FATF requirements, and the regulatory impact that would be imposed on the sector.

The designated service presented in the final Bill focuses on higher-risk money laundering methodologies
through the buying, selling and transferring of real estate, and does not regulate services related to
residential tenancy agreements, property management and leasing of commercial real estate (see item 2 of
Schedule 3 of the Bill). The Bill also does not regulate auctioneer services, unless the auctioning services are
being provided by the seller’s agent alongside brokering the sale of the real estate.

The department has also worked closely with the accounting and legal sectors to ensure designated services
are fit-for-purpose and include appropriate carve outs to reflect money laundering and terrorism financing
risk. For example, following advice from peak accounting bodies and acknowledgement of lower identified
risk, the terms ‘correspondence’ and ‘administrative’ addresses have been removed from the proposed
designated service at item 9 of the new table 6 of the Act (see item 10 of Schedule 3 of the Bill).

Consistent with the designated services model, and in line with stakeholder feedback, the Bill provides
exclusions for those PSP services that are considered lower risk for money laundering and terrorism financing.

Extensive consultation has also been conducted specifically with the legal sector on appropriate protections
for information subject to legal professional privilege. Specific industry concerns have been addressed in
relation to suspicious matter reporting, as well providing greater flexibility on processes for making, reviewing
or disputing assertions about legal professional privilege.

The department has also taken on board a range of feedback from existing reporting entities, including
improvements to customer due diligence risk rating requirements, politically exposed person screening,

12
 Anti-Money Laundering and Counter-Terrorism Financing Amendment Bill 2024 [Provisions]
Submission 1
terminology used for business groups and the head of a reporting group, private-to-private information
sharing, and transitional and commencement timeframes for international value transfer service obligations.

Impact on Industry
The Bill seeks to minimise regulatory impact on both existing and new reporting entities while delivering an
effective AML/CTF regime. The reformed AML/CTF regime is designed to be flexible and responsive to the
nature, size and complexity of a reporting entity and the risks they can reasonably expect to face. The Bill
aims to do this by outlining the principle or outcome to be achieved by regulated business, without using
overly prescriptive or one-size-fits-all procedures.

The impact of AML/CTF regulation will vary significantly depending on the industry and size of the business.
New and existing reporting entities will be able to leverage existing practices and new and emerging
technologies, which will make it simpler and more cost effective to meet their obligations. The Bill also
recognises that AML/CTF policies, procedures, systems and controls would vary according to the nature, size
and complexity of the business. This means the cost of prevention activities and compliance can be scaled to
the size of the business. A small business or sole trader will not be expected to have the same systems and
specialists as a major bank.
The department also recognises that some tranche two sectors are already subject to regulatory oversight or
other professional obligations. Tranche two sectors will be able to leverage and utilise these existing
processes, where appropriate, to meet AML/CTF obligations. For example, many legal practitioners have
existing systems in place to comply with the Australian Registrars' National Electronic Conveyancing Council
(ARNECC) framework to verify their clients’ identities. Legal practitioners who become reporting entities
under the AML/CTF regime may determine that the ARNECC Verification of Identity Standards are sufficient
to meet some AML/CTF customer identification requirements for certain customer types. This would prevent
regulatory duplication and overlap, and contribute to a minimisation of regulatory burden.

Impact Analysis
In line with Australian Government requirements, the department completed an impact analysis that outlines
the impacts and net benefits of the reforms. The department engaged Nous Group to analyse the impacts of
the proposed policy options, including delivering stakeholder surveys on the anticipated changes in
regulatory costs.

The impact analysis estimated the quantifiable benefits of the reforms to be up to $13.1 billion over 10 years,
against an estimated additional regulatory burden to businesses of $13.9 billion over 10 years.
Due to the complex and inherently covert nature of money laundering, accurately quantifying its scale and
economic and societal impacts is challenging in both Australian and global contexts. Illicit finance and money
laundering remain serious threats precisely because they are hidden. Further, the complexity involved in
forecasting any law enforcement and regulatory activity arising from the reforms means that a conservative
approach was taken to quantifying the estimated benefits to ensure robustness.
The full range of benefits is likely to be substantially greater than those that have been able to be directly
quantified in the impact analysis. There is a broad range of criminal activity and second order effects of crime
and national security threats enabled by illicit financing. Additional benefits that could not be robustly

13
 Anti-Money Laundering and Counter-Terrorism Financing Amendment Bill 2024 [Provisions]
Submission 1
quantified include the deterrence of criminal activity by making money laundering more difficult, enhancing
law enforcement ability to combat criminal exploitation arising from expanded regulation of virtual asset
services, reduced inflation of prices for goods and services targeted for money laundering, and increased
consumer trust and reputational benefits for businesses seen as hardened against criminal exploitation.
These are additional to the benefits estimated in the analysis for combatting crime and preventing crime
harm of up to $2.4 billion over 10 years, and avoiding up to $10.7 billion in reduced foreign investment that
could flow from Australia being grey listed by the FATF and seen as a high risk by other countries.
Similarly, the quantifiable costs of the reforms were difficult to ascertain. The estimated regulatory impact
was derived from surveys of businesses, which asked participants to estimate changes in their compliance
costs. The analysis was sensitive to the understanding and assumptions of the affected stakeholders at that
time, including tranche two businesses that do not yet have experience with the AML/CTF regime. Further,
the impact analysis did not factor in the design of the AML/CTF Rules and guidance, which will provide
businesses with operational detail on how obligations should be implemented at a practical level. The
AML/CTF Rules and guidance will be developed with industry, with the aim of minimising regulatory impact
while providing an effective AML/CTF regime. This presents an opportunity to lower the cost of regulation
estimated in the impact analysis. For example, through working closely with industry to understand existing
practice, a higher proportion of existing business process may be able to be used for AML/CTF compliance.
Further, well developed guidance and education from AUSTRAC will reduce the time and effort for small
business to understand and comply with their obligations. It may also reduce or eliminate the need for costly
external advice.
AUSTRAC will work and consult closely with industry on these processes to ensure AML/CTF Rules are flexible
and fit-for-purpose and the associated guidance clarifies businesses’ obligations
The impact analysis received an ‘exemplary’ rating from the Office of Impact Analysis (OIA). The impact
analysis is summarised in the Explanatory Memorandum to the Bill, and is available on OIA’s website.

Deferred commencement
Careful consideration has been given to commencement dates and timings. The Bill contains a sufficient lead
time and staggered commencement dates, to provide adequate time for reporting entities (including newly
regulated entities) to understand and transition to their obligations.

For example, tranche two entities and new virtual asset services would not commence under the AML/CTF
regime until 31 March 2026. The department heard very clearly from stakeholders that they wanted a
considerable period of time to work through implementation, before commencement of obligations.

Schedule 3 of the Bill, which deals with tranche two entities, contains transitional provisions for these newly
regulated entities. These transitional provisions allow tranche two entities that provide new designated
services under Schedule 3 to enrol as reporting entities with AUSTRAC from 31 March 2026, but other
regulatory obligations under the AML/CTF Act would not apply until 1 July 2026.

The commencement dates must also take into account the timing of Australia’s FATF mutual evaluation,
which commences in 2026. If passage of the Bill is delayed, reporting entities (particularly tranche two
entities) will not have enough time to appropriately prepare for their new regulatory obligations. The
measures in the Bill must be in place prior to the mutual evaluation in 2026 to meet technical compliance

14
 Anti-Money Laundering and Counter-Terrorism Financing Amendment Bill 2024 [Provisions]
Submission 1
with the FATF standards. Delaying the Bill will place undue pressure on reporting entities to prepare for and
meet their obligations.

As noted above, failure to address the regulatory gaps in Australia’s AML/CTF regime will increase the risk of
a poor FATF mutual evaluation and a consequent ‘grey-listing’. If Australia is grey-listed, Australia would be
required to implement the substantive elements of the Bill within limited timeframes, while simultaneously
experiencing the economic and reputational grey listing consequences. Australia would have little to no scope
to argue against the measures, as the only way to end enhanced FATF measures or grey-listing is to
demonstrate that the country has made progress and addressed the key non-compliances.

Next steps
AML/CTF Rules
The Bill would amend the AML/CTF Act to contain high-level obligations for businesses, with further detail set
out in the AML/CTF Rules. The development of the AML/CTF Rules will seek to achieve the objectives of the
regime and minimise the regulatory impact on industry.

AUSTRAC will commence engagement and consultation with industry on a draft of the AML/CTF Rules before
the end of 2024.

AUSTRAC guidance and education

AUSTRAC will provide sectors with tailored guidance and education on the new regime. Guidance will be
accompanied by dedicated and diverse engagement channels, including a scaled-up call centre, to address
any questions raised by industry. AUSTRAC will work with industry to develop this guidance to ensure it is fit-
for-purpose and tailored for industries.

FATF 2026-27 Mutual Evaluation

Australia’s next FATF mutual evaluation is scheduled for 2026. The FATF will assess the implementation and
effectiveness of Australia’s AML/CTF measures to combat money laundering, terrorism financing and
financing of the proliferation of weapons of mass destruction.

The department will engage with Australian government and industry stakeholders on preparations for the
FATF mutual evaluation through a range of existing forums at senior and working levels, as well as
establishing specific governance structures to provide oversight and strategic guidance on the preparations.

15