- Advocacy
Joint Submission
The Financial Advice Association Australia (FAAA) and the SMSF Association welcome the opportunity to provide this submission in response to the AUSTRAC consultation on Updates to the New AML/CTF Rules.
We support the proposed amendments to replace the current approach to form a reporting group with
a more streamlined process. This approach should reduce the administrative burden by requiring only the reporting entity that does not want to form a reporting group to ‘opt out’ in writing rather than requiring all reporting entities to agree in writing to form a reporting group.
We also believe it is practical to include the provision that if the reporting entity has taken reasonable steps to ensure the notice is given to all parties, the notice will be taken to be effective.