AML Questions & Answers

What is next? (AML 103) - Sooner than later.

We also have an AML103 in development (again delayed due to AUSTRAC not finalising their program rules and guidelines early enough) that is intended for Principal Brokers or the person who could be either directly or indirectly obligated to put in place an AML/CTF Program that could include oversight for, amongst other things, AML/CTF training, employee due diligence (KYE), supplier due diligence (KYS) and partner due diligence (KYP). The expectation is that Principal Broker would undertake AML101/102 and 103 and a really large brokerage or aggregator with semi-dedicated specialist compliance or operations personnel would also undertake some of the AML104 specialist e-learning.

Material content:
You should be aware that all Deloitte produced materials undergo a rigorous internal ?practice protection? process that may include, amongst other things, a legal review by our internal counsel or other specialist peer review.

The FBAA / Deloitte AML/CTF training program along with FBAA members use of the CTF, Economic and Trade Sanctions (ETS) and PEP name checking capability available only through the AMLcheck™ portal represents good FBAA broker AML/CTF practice.