BT is committed to reducing the risk of financial crime on the businesses and clients who use our products and services.
Financial crime is a very real risk for anyone who owns or operates a business. And it can have devastating impact on customers and communities. A recent PwC study found that 35% of respondents had experienced fraud in the last two years1.
Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Attestation
When distributing our products and services, we rely on Licensees to complete and retain the applicable customer identification procedure under Part 7.2 of the AML/CTF Rules. To support our AML/CTF program, BT asks Licensees to complete a short AML/CTF Attestation every one to two years. Licensees will be contacted by email when it’s time to complete an AML/CTF Attestation (the ‘Attestation’).
BT can provide guidance on the AML/CTF Attestation process, but we can’t provide advice on how to answer the questions.
How to complete an AML/CTF Attestation
- You will receive an email from BT’s Licensee Governance team requesting completion of the AML/CTF Attestation.
- Download AML/CTF Attestation form from this page.
- Complete all questions on the AML/CTF Attestation. For more information on each question, please read our AML/CTF Attestation Support Guide.
- Email a copy to the Licensee Governance team at licenseegovernance@btfinancialgroup.com within 5 business days from receiving the email request.
1. How long do we have to complete the AML/CTF Attestation?
In line with the Terms and Conditions of the Platform User Agreement entered into by the Licensee, the AML/CTF Attestation must be returned within 5 business days after receiving notice to complete it.
2. What questions do you ask in the AML/CTF Attestation?
The AML/CTF Attestation will ask you 9 multiple choice questions about your Licensee’s approach to complying with your AML/CTF obligations. For more information on the questions and how they relate to the AML/CTF Act 2006, please read the AML/CTF Attestation Support Guide.
3. Do I have to complete the AML/CTF Attestation?
Yes, AML/CTF compliance obligations are outlined in the Platform User Agreement in place between BT and the Licensee, and completion of the AML/CTF Attestation is a mandatory requirement.
4. I’m not sure how to answer one of the questions?
In the first instance, we recommend you refer to your Licensee’s compliance representative. If you’re still unsure, you can read our AML/CTF Attestation Support Guide or contact the Licensee Governance team on licenseegovernance@btfianncialgroup.com.
5. Who should complete the AML/CTF Attestation?
The compliance representative in your Licensee is the most appropriate person to complete the AML/CTF Attestation. If we don’t have the correct details for the compliance representative for the Licensee, please email their contact details to licenseegovernance@btfinancialgroup.com, so we can ensure we contact the correct person.
6. How can BT help you with completing the Attestation?
BT can provide guidance on AML/CTF Attestation process, but we can’t provide you advice on how to answer the questions.
If you’re unsure of the steps you need to take, please contact the Licensee Governance team at licenseegovernance@btfinancialgroup.com — they’d be happy to help.
7. What happens if I don’t complete it?
We will send you reminders to complete the AML/CTF Attestation. If we don’t hear from you, we’ll need to take further action — and you may not be able to use the Platform.
8. I have completed the AML/CTF Attestation. What happens now?
Once you have completed the AML/CTF Attestation and sent it to the Licensee Governance team on licenseegovernance@btfianncialgroup.com, we’ll send you an email to confirm we have received it. Completing an AML/CTF Attestation is an ongoing compliance requirement, and the Licensee can expect to be contacted again to complete another AML/CTF Attestation, in 1-2 years.
ACIP Review
All authorised representatives of an AFS licensee must carry out and maintain a record of the Applicable Customer Identification Procedure for each client, in line with AML/CTF obligations.
BT undertake ACIP Reviews as an oversight measure, as part of our reliance on third parties who use our products and services.
You receive a request to complete an ACIP Review
We will send you a list of randomly selected clients, and information on what IDV documents we need for each client
Download our IDV requirements guide on what documentation should be sent to us
Send BT the IDV documentation
You can send the documentation to us via encrypted email using software of your choice, or Fileshare.
Download our Data protection guide on how to send the documentation electronically
IDV documents are reviewed
A member of the Licensee Governance team will review the documentation you sent to us
Allow 10 business days for the review to be completed
Request completed
We’ll send you confirmation that your ACIP Review has been completed.
1. How often will I need to complete an ACIP Review?
ACIP Reviews are a reliance measure we have put in place, that we will ask of you with no set timeframe. However, we expect you won’t generally be asked to complete it more than once every 2 years, unless a specific event occurs.
2. Will the Licensee be asked to do a ACIP Review and AML/CTF Attestation at the same time?
Yes, it is possible, but you won’t generally be asked to complete both at the same time.
3. How long do we have to complete these requirements?
In line with the Terms and Conditions of your platform user agreement, the ACIP Review needs to be completed within 5 business days after receiving notice to complete it.
4. Can we get an extension to complete it?
Extensions will generally only be granted under exceptional circumstances. If you need more time to complete the ACIP Review, please speak to one of the Licensee Governance team members.
The AML/CTF legislation requires a Licensee to provide an ‘immediate response’ to requests of this nature. Our User Agreement allows up to 5 business days.
5. Will I need to do this for each BT platform I have?
Yes. Both platforms will be considered for ACIP Reviews, and the client samples will be across Asgard and Panorama.
6. If the AML/CTF Act has been in place since 2006, why is this happening now?
Like any Commonwealth legislation, the AML/CTF Act is under constant review to ensure it remains contemporary, effective and meets its objectives – for AML/CTF, the legislative objectives are enshrined in law and, supports confidence in the Australian financial system by introducing measures to detect, deter and disrupt financial crimes.
These latest amendments to the AML/CTF Act became law in June 2021 and the industry continues to adapt to the new requirements. And the legislation will continue to be enhanced to respond to global developments and expectations in financial crime
7. What documentation for my clients do I need to provide?
The documentation for each client will be different depending on what type of account they have with you. Please read our IDV requirements guide for more information.
8. How do I send the documentation to BT?
You can send the documentation to us via encrypted email using the software of your choice, or Fileshare. Instructions on how to do either option are outlined in the Data protection guide.
| Findings | Description | What you can do |
|---|---|---|
| Your client’s middle name is missing |
A common issue found during the ACIP review process is the client’s middle names isn’t captured in the BT system during the onboarding process. This can also include the full name not being collected by the adviser on an FSC form (or equivalent). |
When onboarding future clients, please ensure their full name is entered correctly, including their middle name (if they have one), so the information matches during the ACIP Review. |
| Incorrect identification documentation for client on file |
As part of the ACIP review process you’ll need to provide BT with copies of the applicable identification documents that were used to collect information about your client at the time of onboarding, or from the date a designated service was provided. Depending on the date the account was onboarded, the identification documents held on record may now be expired, but the expiry date will still match what was captured in the BT system at the time the account was setup. By law, you’re required to ‘keep customer identification procedure records for the duration of your relationship with the customer, and for an additional seven years after you stop providing any designated services to them.’ |
When providing copies of the identification documents to BT for your ACIP Review, please ensure you send us the documents you used at the time of onboarding, or when the designated service period began. |
| Keying errors |
During the online account onboarding process, keying errors can be a common occurrence when an adviser completes the input of their client’s identification details i.e. driver’s license/passport numbers and expiry dates. |
Ensure you take extra care when capturing your client’s identification details during the onboarding process, to minimise any errors that arise during the ACIP Review. |
Identification requirements for all Licensee staff
To protect the security of client accounts held with us, we require all Asgard and Panorama users who act as an ‘agent of a customer’, including advisers, paraplanners and support staff to complete identification and financial crime screening. Agents should provide us with their residential address, date of birth and other information as ID, as part of our agent onboarding process.
1 Source: PWC Fighting Fraud- A familiar foe in unfamiliar times report pwc-gecs-2020-au-report.pdf