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.
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.
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.
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.
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 firstname.lastname@example.org.
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 email@example.com, so we can ensure we contact the correct person.
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 firstname.lastname@example.org — they’d be happy to help.
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.
Once you have completed the AML/CTF Attestation and sent it to the Licensee Governance team on email@example.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.
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.
Allow 10 business days for the review to be completed
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.
Yes, it is possible, but you won’t generally be asked to complete both at the same time.
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.
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.
Yes. Both platforms will be considered for ACIP Reviews, and the client samples will be across Asgard and Panorama.
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
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.
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.
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