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

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.

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.

Gen­er­ally, all BT customers will be re­quired to com­plete the Customer Due Diligence (CDD) re­quire­ments.  This process re­quires us to:

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

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

Al­ter­na­tively, please con­tact us for fur­ther in­for­ma­tion.

Customers opening a superannuation or investment account will need to submit their application, including proof of identity in the form of acceptable identification documents.

For BT Panorama customers:

• If you are lodg­ing an ap­pli­ca­tion through a fi­nan­cial ad­viser, you may pro­vide a cer­ti­fied copy of identification ver­i­fi­ca­tion doc­u­ments to your ad­viser OR have your ad­viser sight an orig­i­nal copy of your identification doc­u­ments. Your ad­viser will com­plete the CDD iden­ti­fi­ca­tion pro­ce­dure for you.
• Once the identification process has been completed, advised customers must complete the ID verification prompts when accessing the investor website or BT Panorama mobile app. Once these prompts are completed, the application can be submitted.
• Non-advised customers are required to complete the ID verification prompts before their application can be submitted.

If we receive an application without the completed BT Customer Identification Procedure Forms and identification verification record or documents, we will not be able to process the application, unless we have previously identified the customer to our current requirements.

We will contact the customer and/​or their adviser to obtain the required documents. If we do not receive them within 30 days of the application, we will reject the application and return any money received.

If you’re an existing customer, we may ask you to confirm and verify your details are still correct and complete. We may also contact you to update our records with any additional information we require. If this is the case, you will receive communications from us to complete the identification process. If a customer, including beneficial owners and account signatories (where applicable), fail to complete the process within a reasonable timeframe, we may need to apply restrictions to the account until all parties have met our identification standards. We’ll provide ample time and communicate with you before taking any action to restrict your account.

You can choose to either:

1. post the com­pleted BT Customer Identification Procedure Form and cer­ti­fied copies of iden­ti­fi­ca­tion doc­u­ments back to us; or
2. have your fi­nan­cial ad­viser/​plan­ner arrange and com­plete the iden­ti­fi­ca­tion process. Your fi­nan­cial ad­viser will col­lect your iden­ti­fi­ca­tion in­for­ma­tion and pass the rel­e­vant doc­u­men­ta­tion on to us.

BT Panorama accounts

Post the completed form(s) and original certified documents to:

BT Panorama
GPO Box 2861
Adelaide SA 5001

Retail Investment accounts

Post the completed form(s) and original certified documents to:

BT Funds
GPO Box 804
Melbourne VIC 3001

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 Customer Due Diligence pro­ce­dure for you. Please speak with your fi­nan­cial ad­viser for fur­ther information.

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, BT places reliance on the identification and verification procedure performed by a Licensee and their authorised representatives.

Financial Ad­vis­ers opening BT Panorama accounts for new clients have the following choices:

1.  Complete the application, including record of customer identification documents and adviser attestation via BT Panorama Online; or
2. Post to BT, the completed BT Customer Identification Procedure Form including the ‘Verification of ID’ section along with the application form; or
3. Post to BT, the completed BT Customer Identification Procedure Form along with the original certified copies of customer identification and application form.

Fur­ther in­struc­tions are lo­cated on the BT Customer Identification Procedure Form (In­di­vid­ual and Sole Trader) in most Prod­uct Dis­clo­sure State­ments (PDSs) and on this web­site.

All acceptable forms are available in the BT Panorama or Retail Investment Forms section on this webpage. No other Customer Identification Forms apart from those listed on this webpage will be accepted. 

New applicants

Each account holder will need to com­plete the BT Cus­tomer Iden­ti­fi­ca­tion Procedure Form for an in­di­vid­ual/​sole trader and pro­vide the re­quired iden­ti­fi­ca­tion doc­u­ments.

Existing customers

Each account holder is required to update their details by completing a BT Customer Identification Procedure Form and providing the required identification documents. If any customer fails to complete the process within a reasonable timeframe, we may need to apply restrictions to the account until all customers have met our identification standards. We’ll provide ample time and communicate with you before taking any action to restrict your account.

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 BT Customer Identification Procedure 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

Refer to the relevant form in the BT Panorama or Retail Investment Forms section for more information.

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

A certified copy is a document that has been certified as a true copy of an original document. For more information, please refer to the following page bt.com.au/personal/help/how-to-certify-id.html

If you are in­vest­ing di­rectly with BT and do not have a fi­nan­cial ad­viser, you should fol­low the in­struc­tions on the relevant BT Customer Identification Procedure Form in the BT Panorama or Retail Investment Forms section on this webpage.

If you are submitting a new application, your iden­ti­fi­ca­tion doc­u­men­ta­tion should be sub­mit­ted at the same time as your ap­pli­ca­tion to avoid de­lays.

New applicants

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).

Existing customers

If you don’t provide the required details after a reasonable period of time, we may restrict your account until you complete the verification that your details are correct and complete. We’ll provide ample time and communicate with you before taking any action to restrict your account.

If you need assistance to complete this request, you can con­tact us.

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 BT Customer Identification Procedure Form above.

If you need further information, please contact us.

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.

The BT Customer Identification Procedure form for Verifying Officers must be completed. This form can be found in the BT Panorama or Retail Investment Forms section on this webpage.

An Authorised Signatory needs to be identified as an agent of either the individual or non-individual customer. 

1. For appointed Verifying Officers updating Authorised Signatories, the BT Verifying Officer Certification of Agent/Signatory form for the relevant product should be completed. This form can be found in the BT Panorama or Retail Investment Forms section on this webpage. The required information includes: 
   • Full name of the agent
   • Title of the position or role held by the agent
   • Copy of the agent’s signature
   • Evidence of the agent’s authority to act on behalf of the non-individual investor
   • Either one primary photo identity document (either Australian or International), or two types of non-photo identity documents
2. If you are not updating an Authorised Signatory through a Verifying Offer, a BT Customer Identification Procedure Form (Individuals and Sole Traders) should be completed. This form can be found in  the BT Panorama or Retail Investment Forms section on this webpage. If you need further information, please contact us.

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 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.

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 us.

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.

We will re­quire you to carry out cus­tomer iden­ti­fi­ca­tion on our be­half for the pur­poses of AML/​CTF.  BT places reliance on the identification and verification procedure performed by a Licensee.

For BT Panorama only:

Advisers can monitor the status of clients who are required to complete additional identification verification using the Panorama adviser interface or Panorama mobile app. The ‘Client ID and KYC Review’ page provides an online tracker, enabling advisers to view their clients’ identification verification statuses (e.g. pending, completed).

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

1. 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.

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.