• Michael Bacina

Navigating the risks of failure to report to AUSTRAC


AUSTRAC have issued international money transfer business Compass with a hefty infringement notice for $252,000 as a result of Compass failing to report international funds transfers between 2018 and 2019.


Compass was required to provide AUSTRAC with these reports, known as International Funds Transfer Instructions (IFTIs) under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act).


Organisations required to submit IFTI reports to AUSTRAC usually include remittance service providers such as money transfer dealers, international foreign exchange businesses as well as casinos. A failure to submit an IFTI report by a company can result in a fine of up to AUD$21,000,000 and an individual/non-company can be fined up to AUD$4,000,000. In light of the potential maximum penalty Compass seems to have received a relatively light fine.


AUSTRAC publishes infringement notices online, which can have longlasting reputational well after a breach, and in some circumstances can lead to AUSTRAC requiring the appointment of an external audior to review AML/CTF risk management compliance within an organisation.


Piper Alderman has a top shelf team of lawyers well versed in AML/CTF compliance including Andrea Beatty and Michael Bacina.



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