Presentation

• The Three Lines of Defence model for AML has been adopted by major and some domestic Australian banks, but it's not yet consistent across the entire banking sector.

• AUSTRAC’s regulatory focus on casinos, pubs, clubs, and the remittance sector shows that AML risk management in these areas is still developing and often ad hoc.

• Tranche 2 reforms propose adding internal controls to AML/CTF obligations, which may introduce minimum standards for auditors.