The US FATF evaluation report – implications for Australian financial institutions

Australian financial institutions won’t necessarily comply with proposed anti-money laundering and counter terrorist financing laws if they simply adopt the compliance regimes of their US parent entities. Recent Financial Action Task Force evaluation of the US AML/CTF regime which highlights the issues. Partners Anna Lenahan and Peter Jones and Senior Associate Judy Maguire discuss.

The authors are Anna Lenahan, Peter Jones and Judy Maguire at Arthur Allens Robinson.

Introduction

The recent Mutual Evaluation report (the US Report) [hyperlink www.fatf-gafi.org/document/23/0,2340,en_32250379_32237217_37101591_1_1_1_1,00.html] of the US anti-money laundering and counter terrorist financing (AML/CTF) regime by the Financial Action Task Force (FATF) has concluded the US AML/CTF regime is only partially compliant with some of the FATF Forty Recommendations and Special Recommendations on Terrorist Financing, in particular those recommendations which deal with customer due diligence and suspicious transaction reporting.