AML/CTF Documents (Digital Currency Exchange) - AFSL, Wholesale

Before providing a designated service, a business is required to have in place an Anti-Money Laundering and Counter-Terrorism Financing Program (AML/CTF Program).

Your AML/CTF Program and other associated documents must set out how you will comply with your obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and Anti-Money Laundering and Counter-Terrorism Financing Rules 2007 (Cth).  This includes your AML/CTF-related processes, checks and procedures.

Do you know what your obligations are?

Do you comply?

Your AML/CTF Program must be based on your Money Laundering/Terrorism Financing (ML/TF) Risk Assessment, which assesses the risk that your business could be used for money laundering and/or terrorism financing, and sets out the controls that you have implemented to control this risk.  Your AML/CTF Program should include all of your AML/CTF-related processes, checks and procedures.

Amongst other things, your AML/CTF Program will need to include specific details in relation to:

• how you will comply with your reporting obligations, (and the systems and controls to ensure compliance with those reporting obligations);
• your business’ AML/CTF risk assessment;
• your risk-based systems and controls to monitor customer transactions; and
• the identification procedures which apply to your customers.

This template reflects the generic obligations of businesses providing digital currency exchange services, and must be tailored to reflect your business.