It looks like AUSTRAC are going to be as helpful as possible in the process of you assessing your AML / CTF risk if the release today of their Self Assessment Questionnaire (warning – 2MB MS Word document) is any guide to the future. It is big, at 46 pages and, in parts, fairly intimidating, but it does break the Act and Rules down in a handy, systematic way.
For the smaller players in the market this will be a useful guide and a good way to do the gap analysis (if you have a few days) but you will still need to get some external advice as a sense check – particularly if you are in any doubt. The sheer length of the document also shows how much needs to be done over the next 18 months to two years.
Also, for the banking organisations out there, while you are going through this try to think how you can bolt some of this on to the operational risk work you have been doing for Basel II compliance. Money laundering or terrorist financing are clearly operational risk events and should be identified and treated as such.
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