Anti-Money Laundering (AML) and Counter Terrorism Financing (CTF)

The Government has introduced new anti-money laundering and counter-terrorism financing laws to reduce the risk of Australian businesses being misused for the purposes of money laundering or financing terrorism.

These changes were introduced into Australia by the Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) Act 2006, bringing Australia in line with international standards.

As a result of the new legislation, BT Financial Group (BT), along with other financial services organisations, changed the way we verify the identity of customers from 23 February 2009.

The question and answer section below provides further information.

Investors and general information

What are the new identification requirements?

Generally, all new BT customers will be required to complete the AML/CTF identification requirements.

The customer identification process is commonly referred to as 'Know Your Customer' (KYC), and requires us to:

  • Ensure that our customers are properly identified through documented processes
  • Verify the identity of customers using reliable and independent documentation

The identification requirements will vary between BT products and investor types, please refer to the questions below for additional information.

Alternatively, please contact BT Customer Relations on 132 135, 8.00am to 6.30pm (Sydney time) Monday to Friday.

When do new customers need to be identified?

The legislative requirements for providing identification changes depending on the product the customer is applying for.

Superannuation Products

Generally speaking, superannuation customers will need to identify themselves when they make a cash-out (full or partial redemption) from their superannuation investment not when they make an application.

However, customers wishing to make an application into SuperWrap and/or SuperWrap Essentials are required to provide identification at the time they make an application.

General Investment Products

Customers investing in an investment product will need to provide identification when they make an application.

If we receive applications without the completed Customer Identification Forms and verification record or identification documents, we will not be able to process the application, unless you have previously been identified under the new AML/CTF rules.

We will contact either you and/or your adviser to obtain the required documents and if we do not receive them within 30 days of the application we will return your money.

If you were a BT customer prior to 23 February 2009 you may not need to be identified again. Please contact BT Customer Relations on 132 135 for further information.

The table below shows when identification needs to be provided for specific BT products.

When applying... When cashing out...
Wrap & SuperWrap BT Lifetime Super Employer Plan
Wrap Essentials & SuperWrap Essentials BT Business Super
BT Investment Funds BT Lifetime Personal Super
BT Investor Choice  
BT Lifetime Flexible Pension  
BT Wholesale Multi-manager & Partner Funds  

How will I know if I need to complete the Customer Identification Forms?

Existing customers

Generally, existing BT customers, prior to 23 February 2009, are not required to provide identification documentation.

If there is an exceptional situation that requires us to obtain proof of identification from an existing customer, we will advise that customer or their financial adviser.

If you have provided a Customer Identification Form to BT after 23 February 2009, then you do not need to complete another form unless your details have changed.

Applying for a new product or service

If you are making a new investment in the same name as your existing investment, you should not need to provide any identification documentation.

However, if you have an existing BT investment in one name and you want to make a new investment in a different name, you will have to provide identification information as required.

For example:

You have an existing investment in the name of 'J Blogs A/C ABC Super Fund' and you now want to make a new investment for yourself, Joe Blogs.

In this example, under the new legislation, you are required to provide identification information.

How do I complete the identification process?

New BT investors can choose to either:

  1. mail BT a completed Customer Identification Form and attach certified copies of identification documents; or
  2. have their financial adviser/planner arrange and complete the identification process. The financial adviser will collect the investor's identification information and pass the relevant documentation on to BT along with the investor's product application form; or
  3. complete the identification process at their nearest Westpac branch. The Westpac Customer Identification Standards are different from those detailed on the BT Customer Identification Forms.

(Note that existing BT or Westpac investors making a new BT investment may not need to be identified again for AML/CTF purposes. Please refer to the question "When will investors/advisers start using the Customer Identification Forms?" for more information).

Why are Westpac Bank branches able to complete the identification procedure on BT's behalf?

BT is the wealth management arm of Westpac Banking Corporation, and as such, BT and Westpac are working together to help meet the Anti-Money Laundering and Counter Terrorism Financing (AML/CTF) obligations faced when new investors join. This cooperation means that investors new to BT have the convenient option of having the identification procedure conducted at any Westpac Branch.

What do I need to do to complete the identification process at a Westpac Branch?

BT investors must complete the following steps to be identified through a Westpac branch:

  1. Complete the relevant product application form in the relevant Product Disclosure Statement, ensuring any applicable application documentation is provided. Investors must take their product application form* with them to the branch
  2. Present suitable identification documents as per the table below, in person, at a Westpac branch
  3. Westpac staff will complete the identification process
  4. BT investors can choose to submit the product application forms through the branch or mail them directly to BT

*Online Applications
Please note that investors who have submitted a product application online (BT Investment Funds only) will be required to take their Transaction Details receipt (containing your Reference Number) when visiting a Westpac branch for the AML ID&V process.

What documents are accepted by Westpac in order to meet its Customer Identification Standards for a personal customer or sole trader?

The Westpac Customer Identification Standards list the types of documents that can be used for identification when completing the identification process at your nearest Westpac branch.

You must show at least ONE document from Table A and where unable to provide a document from Table A then ONE document from Table B AND ONE document from Table C.

The documents must include:

  • Your Full Name on each document, your Date of Birth must appear at least once across the TWO documents provided
  • All documents must be current unless specified otherwise
  • If any document is written in a language other than English, you must provide an English translation prepared by an accredited translator
Table A - Primary identification document
  • Australian passport (can either be current or expired within the last 2 years but must not be cancelled, defaced or mutilated)
  • Foreign passport issued by a foreign government, the United Nations or an agency of the United Nations (must not be cancelled, defaced or mutilated)
  • Foreign travel document issued by a foreign government, the United Nations or an agency of the United Nations
  • Australian licence/permit (can either be a driver's licence, learner's permit)
  • Foreign driver's licence which contains a photograph
  • Proof of age card issued by a State or Territory (or equivalent)
  • National identity card issued by a foreign government, the United Nations or an agency of the United Nations

*All documents must contain a photograph and signature.

 

Table B - Primary Non-Photographic Identification documents
  • Full Australian birth certificate (or extract) issued by State/Territory Registry of Births, Deaths and Marriages
  • Full Foreign birth certificate issued by a foreign government, the United Nations or an agency of the United Nations
  • Australian citizenship certificate
  • Citizenship certificate issued by a foreign government
  • Centrelink pension card (Australian)

 

Table C - Secondary identification document
  • A financial benefits notice issued by the Commonwealth or a State/Territory within the last 12 months and includes the customer's name and residential address (e.g. a notice from Centrelink)
  • Australian Taxation Office (ATO) notice issued within the last 12 months and includes the customer's name and residential address
  • Utilities notice issued by a local government or utilities provider within the last 3 months and includes the customer's name and residential address
  • Foreign driver's licence which does not contain a photograph
  • Department of Veterans' Affairs pension concession card (Australian)
  • A current tenancy/lease agreement (must not be cancelled or expired)
  • Medicare card
  • Australian Marriage certificate issued by State/Territory Registry of Births, Deaths and Marriages
  • Identification card issued to a student at an Australian higher education institution (TAFE or University)^
  • Notice issued by the principal of a school (must be less than 3 months old, include the name of the customer, residential address, period of school attendance and issued on a school letterhead)
  • A current card issued under a Commonwealth, State, or Territory law for the purpose of identification, for a government service, or as a licence

^ must contain photograph and/or signature

How do I find my nearest Westpac branch?

Westpac branches can be located through the Locate Us online service or call Westpac on 132 032.

I have a financial adviser, do I need to complete the AML/CTF requirements?

If you are lodging an application through a financial adviser, you may provide a certified copy of verification documents to your adviser OR have your adviser sight an original copy of your documents.

Your adviser will complete the AML/CTF identification procedure for you. Please speak with your financial adviser for further information.

When are investors/ financial advisers required to start using the Customer Identification Forms?

This new requirement came into effect at BT from 23 February 2009.

Generally, existing BT or Westpac investors who are investors prior to 23 February 2009 will not be required to complete the Customer Identification Form. BT Customer Relations can assist further if required, please call with your BT/Westpac account details ready, 132 135, 8.00am to 6.30pm (Sydney time), Monday to Friday.

Generally, if you provide a completed and accepted Customer Identification Form to BT after 23 February 2009, you will not need to complete another Customer Identification Form unless your details have changed or you invest under a different entity structure.

Any new product applications we receive, on or after 23 February 2009, from new investors, must be accompanied by the required customer identification documentation, unless a Westpac branch performs the identification process. Please refer to 'How to be identified through a Westpac Branch' for further information.

What are the requirements of financial advisers under AML/CTF?

Advisers are bound by a set of key obligations to identify and verify that their client is who they say they are; referred to as Know Your Customer (KYC). For the purposes of the AML/CTF Act, financial advisers are generally appointed as agents to carry out any customer identification and verification procedures required by BT in relation to applications.

Advisers have two choices. They can either complete the 'record of verification procedure' section in the Customer Identification Forms and send this to BT along with the product application form, or send in copies of customer identification documents. Further instructions are located on the BT Customer Identification Forms (Individual and Sole Trader) in most Product Disclosure Statements (PDSs) and on this website.

Generally BT will only accept correctly completed forms that were jointly produced by the Investment and Financial Services Association (IFSA) and the Financial Planning Association (FPA). However, other Customer Identification Forms which are based on the IFSA/FPA form will still be accepted if all the required information has been included.

What Customer Identification Forms will BT accept?

BT will accept:

  1. the Customer Identification Form (for Individual and Sole Traders only) located in most of our PDS's;
  2. other entity customer identification type forms; and
  3. correctly completed forms that were jointly produced by the Investment and Financial Services Association (IFSA) and the Financial Planning Association (FPA).

Will BT accept other Customer Identification Forms?

All acceptable forms are available here under the Forms tab.

For individuals or sole traders, the correct Customer Identification Form is also included in the majority of Product Disclosure Documents (PDS).

Generally BT will only accept correctly completed forms that were jointly produced by the Investment and Financial Services Association (IFSA) and the Financial Planning Association (FPA). However, other Customer Identification Forms which are based on the IFSA/FPA form will still be accepted if all the required information has been included.

To avoid any delays or confusion we strongly suggest you use the industry developed IFSA/FPA Customer Identification Forms.

If a joint investment is being opened, do both investors have to fill out a Customer Identification Form?

Yes. Joint investors each need to complete the Customer Identification Form for an individual/sole trader and provide the required identification documents.

I am a Westpac customer and have previously completed an identification process with them. Do I have to complete the new Customer Identification Form?

If you have previously completed the proof of identification process with Westpac, you may not have to complete another Customer Identification Form as long as:

  1. Your name is unchanged;
  2. You are applying for a BT product under the same entity type ( e.g. an individual or a trust or a company);

Please contact BT Customer Relations on 132 135 if you are unsure if you must complete the identification process.

Which products and services are covered by the new legislation?

All financial services providers offering products such as managed funds, superannuation, pensions and bonds, must meet the new customer identification requirements. As such, all BT products (except Life insurance) will be covered.

What changes have been made to our application process?

BT will insert a BT Customer Identification Form ( for Individuals and Sole Traders only) into both our printed and web-based PDSs

In addition, an AML/CTF checklist has also been provided in our PDSs, to ensure your product application, Customer Identification Form and any required identification documents are provided correctly

If you are not an individual/sole trader, and require customer identification forms for a different entity, please download the appropriate form or contact BT Customer Relations on 132 135.

What identification information does a new customer need to provide?

This depends on whether you are investing as an individual, company, partnership or other entity.

Each customer will need to provide us with specific information outlined in the relevant Customer Identification Form. There are different forms for different entity types as follows

  1. Individuals and Sole traders
  2. Trusts
  3. Partnerships
  4. Australian/foreign companies
  5. Associations
  6. Government bodies
  7. Registered co-operatives

What forms of identification do I need to provide?

The types of acceptable identification (ID) documents are dependent on how you are setting up the investment. The 'Verification Procedure' section in the Customer Identification Form will list the acceptable types of ID documents or options available to you.

Below is an example for individual and sole trader investors.

aml-screen1.gif

AND tick and select one valid option from this section

aml-screen2.gif

What is a certified copy and who can certify copies of documents?

A certified copy is a document that has been certified as a true copy of an original document.

To certify a document, take the original document and a photocopy to one of the people listed in the categories below and ask them to certify that the photocopy is a true and correct copy of the original document. That person will need to print their name, date and the capacity in which they are signing (e.g. postal agent, Justice of the Peace). Sample wording is provided below.

aml-screen3.gif

Please note that a financial adviser can certify a customer's identification documents if they are 'an officer with, or authorised representative of a holder of an Australian financial services licence, having two or more continuous years of service with one or more licensees'.

Can I go to Australia Post to have the copies of my identification documents certified?

Yes, there are two types of Australia Post personnel who are able to do this. They are:

  1. a person who has been an employee of the Australian Postal Corporation for two years or more, or
  2. an agent of Australian Postal corporation who is in charge of an office supplying postal services to the public.

How do I provide BT with my identification documentation?

If you are investing directly with BT and do not have a financial adviser, you should follow the instructions on the Customer Identification Form (individuals and sole traders) included in the relevant Product Disclosure Statement (PDS) or other entity type customer identification forms located on this webpage. Your identification documentation should be submitted at the same time as your application to avoid delays.

What if I don't provide the required identification?

Your request will be deemed as invalid and the transaction will not be processed until valid documentation is received. The usual rules around cut-off times apply, please refer to your Product Disclosure Statement (PDS).

Do the identification requirements differ for each product?

The requirements are the same for all BT products.

The only difference in the process is in the timing of when you need to provide identification information to BT.

Please refer to the table below for the identification requirements of your product:

When applying... When cashing out...
Wrap & SuperWrap BT Lifetime Super Employer Plan
Wrap Essentials & SuperWrap Essentials BT Business Super
BT Investment Funds BT Lifetime Personal Super
BT Investor Choice  
BT Lifetime Flexible Pension  
BT Wholesale Multi-manager & Partner Funds  

What are the ID&V requirements for requesting a Transfer of Ownership?

The investor that the product is being transferred to must be identified. If the investor that the product is being transferred to is an existing investor then no additional identification is required.

Where a product is transferred to a new investor, a Transfer Form will need to be accompanied by a Investor Identification Form located on this website. Transfer Forms can be requested by calling BT Investor Relations on 132 135.

Do non-individual investors need to appoint an identified Verifying officer to update Authorised Signatories?

No. Appointing a Verifying Officer is optional. For banking products appointing a Verifying Officer makes it easier to appoint and change signatories to a non-individual account. For wealth products however, appointing a Verifying Officer makes very little difference to the amount of information required to add or change a signatory.

What are the identification requirements for Verifying Officers?

There is an Identification form for Verifying Officers that must be completed. This form can be found on the BT website and contains information on the obligations of a Verifying Officer as well as instructions for identification.

What information needs to be supplied by an Authorised Signatory?

An Authorised Signatory needs to be identified as agents of the non-individual investor. In order for us to identify an Agent for an account, we need to collect their name, signature, and evidence of their authority to act on behalf of the non-individual investor.

What are the identification requirements for Cheque book signatories?

All signatories to a chequebook must be identified at an individual level, unless the signatory has previously been identified by us. This includes all signatories to a new chequebook as well as adding signatories to an existing chequebook. The signatories should complete the Customer Investor Identification Form for individuals and sole traders. This new identification process replaces the old S21 process that existed under the FTRA requirements.

Advisers FAQs

What is the AML/CTF legislation?

The Anti-Money Laundering / Counter-Terrorism Financing Act (AML/CTF) is aimed at detecting and preventing money laundering in Australia and the threat to national security caused by the financing of terrorism.

The new regulations have been designed to bring the Australian Financial Services Industry into line with international best practice in detecting and deterring money laundering and the financing of terrorism.

Where can I find out more information?

The Australian Transaction Reports and Analysis Centre (AUSTRAC) is the regulator of the new legislation. You can visit their website at www.austrac.gov.au to get more information.

If you need further information please contact BT Adviser Relations on 1800 025 127 or, for Wrap enquiries, Wrap Adviser Relations on 1300 360 899.

Does the AML/CTF legislation apply to me?

As you provide 'designated services' to your clients, the AML/CTF provisions apply to you.

You will be bound by a set of key obligations to identify and verify that your client is who they say they are; referred to as Know Your Customer (KYC).

These provisions apply equally whether your client is an individual, a company, trust, partnership or some other entity.

This means that, as our agent, you will be required to capture and verify customer identification information.

This is similar to the existing process for identifying and verifying customers when they open their first bank account, which you and your clients will already be familiar with.

Different product and platform providers may differ in their approach and timing for implementation of AML/CTF obligations. Therefore you should check to ensure you are clear about what each provider may require.

What do I need to do now?

We will require you to carry out customer identification on our behalf for the purposes of AML/CTF.

We intend to align our approach with industry standards (IFSA/FPA) to ensure minimum impact on you and your clients as well as providing a consistent client experience across the industry.

We recommend that you familiarise yourself with the IFSA/FPA Guidelines for identification and verification of customers.

What is an FSC/FPA Customer Identification Form?

In recognition of the fact that many financial advisers deal with multiple product providers, the Financial Services Council (FSC) and Financial Planning Association of Australia (FPA) aim developed industry standard forms to be used for the purposes of identifying clients.

How can I check whether an existing client will need to complete the identification process?

As a general rule you should submit an IFSA/FPA Customer Identification Form or equivalent each time you send in a client application form to avoid delays and confusion. However, there may be exceptional cases where an existing client to BT may not need to complete the identification process.

To determine this please consider the following points:

  1. Was the client a BT customer prior to 23 February 2009?
  2. Is the client applying for a new investment (or redemption in the case of superannuation) in the same name as their existing investment?
  3. In the case of superannuation accounts, is the client making a cash-out and have they been identified and verified?
  4. Are they applying under the same entity type i.e. trust/individual/sole trader/ company)?

If the answer to any of the above questions is 'No' then the client must complete the relevant customer identification documentation.

If you need further information please contact BT Adviser Relations on 1800 025 127 or, for Wrap enquiries, Wrap Adviser Relations on 1300 360 899.

I have already completed a Customer Identification Form with other product providers for my client. Can I submit a copy of this form to BT?

Yes you can. As long as the entity type of the IFSA/FPA Customer Identification Form is the same as on the application form.

Can I certify my client's copies of their identification documents?

If you meet the following criteria then you can certify copies of identification documents for your client:

  1. If you are an officer with, or authorised representative of a holder of an Australian financial services licence and
  2. have two or more continuous years of service with one or more licensees

What is a designated service

The AML/CTF Act regulates the provision of the following designated wealth management services:

  1. Acting as an agent for the acquisition or disposal of securities or derivatives.
  2. Issuing or selling a security or derivative (i.e. managed investment scheme).
  3. Accepting payment for the establishment of a new pension or annuity.
  4. Making a payment to a person under a pension or annuity.
  5. Accepting a contribution, roll over or transfer into a superannuation fund (other than SMSF).
  6. Cashing the whole or a part of an interest in a superannuation fund (other than SMSF).
  7. Providing a custodial service.
  8. Making arrangements for a person to receive a designated service as an AFSL holder.

Forms

Form for individuals and sole traders

If you are an individual or sole trader, use this form:

  1. An individual or sole trader

Form for verifying officers

If you are appointing a new verifying officer, use this form:

  1. Verifying officers

What are the definitions of each entity type?

Association

An association can be:

  1. An incorporated association - a group of persons who have agreed to join together in pursuit of one or more common objectives, which is incorporated in accordance with State, Territory or overseas legislation
  2. An unincorporated association - a group of persons who have agreed to join together in pursuit of one or more common objectives, which is not incorporated

Domestic Company

A domestic company can be:

  1. A domestic proprietary company - a company incorporated in Australia that is limited by share capital, has no more than 50 non-employee shareholders and has not raised money from the public
  2. A domestic public company - a company incorporated in Australia and is entitled to raise funds by offering securities in itself to the public
  3. A listed domestic public company - a public company incorporated in Australia whose securities are listed (quoted or priced) and freely traded on an official list of a financial market or exchange in Australia

Foreign Company

A foreign company can be:

  1. A foreign public company - a company incorporated outside of Australia entitled to raise funds by offering securities in itself to the public. This company may or may not be registered in Australia by ASIC.
  2. A foreign proprietary company - a company incorporated outside of Australia which is a private/proprietary company in accordance with the requirements of the jurisdiction in which it is incorporated. This company may or may not be registered in Australia by ASIC and may or may not be registered in the jurisdiction in which it is incorporated.

Government Body

A government body can be a domestic or foreign government body:

  1. Domestic government body - an agency or authority of the Commonwealth, a State or a Territory
  2. Foreign government body can be either:
    • a government of a country
    • an agency or authority of the government of a country
    • a government of part of a country
    • an agency or authority of the government of part of a country

Individual and Sole Trader

An individual is a natural person of any nationality. A sole trader is a natural person who trades in their own legal right without the use of a company structure, incorporation or partners and who, alone, has full liability for the activities of the business. Sole traders can operate under their own name or register a trading name.

Partnership

A partnership is the relationship that exists between persons (the partners) carrying on business in common with a view to profit. The rights of the partners between themselves are governed by a partnership agreement.

Registered Cooperative

A registered cooperative is a legal entity owned and controlled by the people for whom it was established and who benefit from using its services. Cooperatives may be set up for a very wide range of social and economic activities, such as retailing, agriculture, manufacturing, child care, housing, marketing, arts and crafts and taxi services. Cooperatives may be registered by a relevant State, Territory or overseas body.

Trust

A trust is a relationship which exists where the trustee holds property or assets for the benefit of the beneficiary. The trustee can be an individual, group of individuals or a company. There can be more than one trustee and there can be more than one beneficiary.