AML/CTF changes – impacts for clients and advisers

Before we can provide services to you, we will be required to complete a due diligence process in accordance with the AML/CTF laws.

The due diligence process will require us to do the following before establishing the new entity:

• verify the identity of individuals involved in key positions for the new entity (such as directors, shareholders, appointors or beneficiaries)
• where existing entities are involved in a new structure (e.g. as a shareholder of a new company):
  • verify the identity of any individuals involved in those entities (e.g. directors, shareholders, appointors or beneficiaries)
  • obtain copies of governing documents for those entities.  

We will be using a third party provider, First AML, to assist with this process and it will typically require the relevant people to answer some questions and upload photo ID.
 

What is changing?

When applying for a new entity:

• there will be additional information you are asked to provide in the online portal
• when you submit a new entity through the checkout, our verification of identity process will commence via our third party provider, First AML
• the nominated contact will receive an email that enables the relevant individuals to complete the First AML verification of identity process.  

As the due diligence process will take some time to complete, this will cause some delay before the new entity can be established. Ensuring the relevant individuals complete the First AML verification of identity process promptly will enable us to establish your entity as soon as possible.

There will also be costs involved in completing the verification of identity process and all the associated searches required to comply with the AML/CTF laws. These costs will be passed on to you in addition to the costs to establish the new entity.
 

Reliance agreements

If your business is also registered with AUSTRAC, we may be able to enter into a reliance agreement with your firm. The benefits of a reliance agreement include:

• the relevant individuals will not need to complete the verification of identity process with us
• your new entities will be established on the same day your application is received, if received before midday. 

However, a reliance agreement will only be of benefit where you have completed a verification of identity and risk assessment process in accordance with the AML/CTF laws for all relevant individuals involved (directly or indirectly) in the new entity. If you are relying on concessions for a continuing client, we will need to separately complete the due diligence process even though you do not.

You can register your interest in entering into a reliance agreement using the form below.
 

Working together to make the process as smooth as possible 

We appreciate that the AML/CTF changes create additional administration for everyone involved. CGW Structures will work with you to ensure the process runs as smoothly and efficiently as possible, and we will continue to refine the process over time.

Please contact us if you have any feedback or questions as we get started with these new processes.