000 SSAMM AML AUSTRAC audit checklist issued 25th September 2008

SSAMM Management Business Consultants Pty Ltd ACN 085 294 257 Quay West Business Centre SSAMM L2, 102 Gloucester Street Sydney NSW 2000 Australia management consulting Tel: +61 2 9247 0160 Fax: +61 2 9247 4080 www.ssamm.com.au th25 September 2008 Anti-Money Laundering and Counter-Terrorism Financing Act (2006): AUSTRAC Audit SSAMM Management Consulting (SSAMM) supports many clients to meet their compliance obligations, such as compliance with the AMI/CTF Act. This outline is in response to requests from various financial services’ clients facing forthcoming AUSTRAC audits. Note AUSTRAC may conduct a combination of desk reviews of information collected via the lodgement of compliance reports or requests for information made by them. AUSTRAC also conduct on-site audits at the offices of reporting entities. Risk Based Approach to Compliance reporting As you may know the AML/CTF Act takes a risk based approach to compliance. Those steps include but are not limited to the following: 1. Preparations A reporting entity must ensure that a risk assessment has been undertaken and fully documented. This needs to be done for each reporting entity within a designated business group. Risks that should be assessed include: governance risks, operational risk, IT and systems risk, outsourcing risk, agency risk, regulatory compliance risk, business planning risk, customer type risk, product risk, channels of distribution risk, jurisdictional ...