Having trained and qualified in London, Kamal has gained significant exposure to servicing a broad range of clients and industries in different jurisdictions.

Kamal is a Registered Company Auditor and is experienced in providing audit and assurance services to publicly listed entities, international groups and not-for profits in a variety of industries. With a diverse portfolio of clients, Kamal is passionate about providing audit, assurance and advisory solutions that deliver forward thinking commercial, innovative and value add outcomes to help his clients unlock their potential and achieve their ambitions. Kamal advocates the use of smart technologies in the assurance service delivery so as to achieve a higher quality of output and allowing the team to focus on the objectives of an engagement.

His clients are from a diverse cross-section of industries and therefore his significant industry experience includes mining, technology, financial services, manufacturing, retail, hospitality and entertainment & media sectors.

Kamal’s experience includes:

• External audit and assurance services
• International Accounting Standards, Corporations Act and ASX Listing Rules interpretation and advice
• Accounting for complex transactions
• Financial reporting and financial statement preparation
• Corporate governance
• Risk advisory, systems and technical reviews
• Real estate & solicitor’s trust audits
• Internal audit & SOX
• CFO and outsourcing solutions

Kamal is a Partner of SW Audit and a Director of SW Accountants & Advisors Pty Ltd.

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With the news regarding SkyCity, AUSTRAC has cited ‘systemic failures’ in the operator’s anti-money laundering and counter-terrorism financing (AML/CTF) programs, particularly regarding the failure to have a transaction monitoring program and to carry out appropriate ongoing customer due diligence, including on some very high-risk customers.

Australia’s thriving pub and club industry is not exempt from scrutiny. Electronic gaming machine operators, including pubs and clubs with electronic gaming machines (EGMs) are required to actively mitigate and manage their money laundering and terrorism financing (ML/TF) risks. Business with entitlement to operate 15 or less EGMs may be exempt from some obligations, however they must still enrol with AUSTRAC and report suspicious matters.

AML/CTF requirements for gaming machines operators

Pubs and clubs with EGMs should ensure they have/do the following:

• Complete a risk assessment to identify money laundering and terrorism financing risks your business faces and tailor your AML/CTF program to the business.
• Collect and verify ‘know you customer’ (KYC) information.
• Have a transaction monitoring program.
• Have ongoing customer due diligence and carry out additional checks on higher risk or suspicious customers.
• Report suspicious matters to AUSTRAC e.g. if you suspect a person is linked to crime or a customer is not who they claim to be. Low reporting compared to peers may indicated an ineffective AML/CTF program.
• Do not tell customers that you have reported them in a suspicious matter report (SMR).
• Maintain accurate records of transactions e.g. a cheque register of payouts.
• Have processes so that staff working on the gaming floor can help to identify and report suspicious behaviour.
• Have an employee due diligence program.
• Submit annual compliance reports to AUSTRAC.
• Notify AUSTRAC of any changes such as a new compliance officer or updated contact information.
• Undertake regular independent reviews of Part A of your AML/CTF program.

How can SW help?

Our highly experienced team works closely with organisations across multiple industries, including the tourism and hospitality sectors, to ensure their AML/CTF programs are compliant  and appropriate to the needs of the business. We can review your current programs and processes, advise where the gaps are, or review your  compliance with AML/CTF requirements.

Reach out to our experts for an obligation free discussion about your current program, details about how we can help with a review of your AML/CTF program and provide tailored recommendations.

Contacts

Laura Toscano

The post Gaming machine money laundering: What do operators need to do to comply with AML/CTF Laws appeared first on SW Accountants & Advisors.

Our teams work deeply in each sector, so have an innate understanding of key risks, pressures from key stakeholders, changing legislation requirements, budgeting and finance constraints and emerging issues that require closer scrutiny.

We will always strive to foster a high level of engagement and communication between our core team and your internal audit and risk team. We aim to become an extension of your team rather than seen as an external provider.

We seek to understand your broader strategic plan to ensure that our audits and advisory work underpins the drivers for your success.

With our experience in delivering internal audit services for a significant number of State and Local Government clients and the private sector, our partner-led teams provide:

• a fresh perspective with a focus on continuous improvement and innovation to enhance your ability to deliver on your important public purpose and strategic agenda
• an insight into better practices from working with our diverse range of clients from different industry sectors
• enhanced data analytics to provide you with unique insights into how you can better utilise your data to improve decision making and strengthen your control framework.

To confidently approach the future, you also need to be aware of the risks you’re facing and implement strategies for the long-term rather than just focusing on the day to day. Our risk management advisors can work with you to identify and mitigate immediate risks, but can also work with you to conduct in-depth reviews of operational and business risks, leading to a clearer picture of where the company needs to focus to reach its strategic objectives.

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Following criticism and concern regarding Australia’s customer due diligence requirements, amendments to the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act) were passed by parliament in December 2020, and these came into force on 18 June 2021.

The changes bring Australia into compliance with the standards published by the Financial Action Task Force (FATF), an international, inter-governmental body which develops and monitors policies to combat money laundering and terrorist financing.

The Act empowers AUSTRAC, Australia’s AML regulator, with a range of measures to detect and deter money laundering and terrorism financing, including monitoring a reporting entity’s AML/CTF program, independent reviews and compliance reporting.

Through working with clients for over 20 years to streamline financial crime prevention processes and controls, our experts have a deep understanding of both the business structures of financial and other reporting institutions, and the regulatory compliance requirements that AUSTRAC will enforce.

What are the changes?

Several changes were made to improve collaboration and information sharing between agencies, increase due diligence obligations, streamline cross-border currency provisions, and in some areas reduce costs and regulatory burden.

Typically when conducting AML /CTF reviews we have helped organisations improve their AML/ CTF control framework in the following areas:

• Appropriate Know Your Customer (KYC) risk assessment processes
• Strengthening of gaps identified in the policy and procedure framework
• Automated controls around monitoring of suspicious transaction activity, and
• Effectiveness of sanctions and Politically Exposed Persons (PEPs) screening including processes in place to monitor Australian blacklists / watch lists.

How we can help?

Reporting entities, particularly ADIs and other financial institutions operating in Australia, must ensure the business has robust policies, procedures and controls in place through an AML/CTF Program to help it prevent, detect and report instances of money laundering and terrorism financing that might occur through the legitimate products and services the business offers.

The Program is required to be independently reviewed for compliance regularly.

• Is your AML/CTF Risk Assessment up to date and does it adequately identify your risks?
• Does your AML/CTF Program cover the updated requirements set out by the AML/CTF Act and Rules?
• Have you commissioned an independent review of your AML/CTF compliance in the last two years?

Contacts

Get in touch to talk to an expert about a specialist AML/CTF program review.

Laura Toscano

For further information see the AUSTRAC reforms guidance.

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