Moody’s Talks: Risk Reframed

Tranche 2: The future of AML & CTF


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Australia recently passed an amended anti-money laundering and counter-terrorism financing (AML/CTF) bill that will soon include Tranche 2 entities in its regulatory regime. 

The result? Approximately 100,000 new entities under its scope. 

Regulating non-financial entities is not a new undertaking, as we’ve seen in countries like the UK, Singapore, and United Arab Emirates. Crucial to the success of the regime and overall client experience will be how Australian firms adopt the best practices shown by firms in other parts of the world, while ensuring they account for the nuances of their domestic market.

In this episode of KYC Decoded, risk advisory lawyer, Jeremy Moller, from Norton Rose Fulbright and Qing Liu, Moody's Senior Director of Compliance & Third Party Risk in Australia, sit down with host Alex Pillow to discuss what the anticipated changes mean for Tranche 2 obliged entities and the future of compliance in Australia.

Key topics:

  • Introduction of the Tranche 2 regulations
  • Challenges and opportunities for firms implementing the reforms
  • International comparisons of similar regimes, and opportunities for harmonizing regulations

Additional resources:

  • Register for Moody’s in-person Sydney event on April 3 – the event features a blend of plenary and breakout sessions led by industry peers and Moody’s financial crime practice lead.
  • Law Council of Australia: AML/CTF Guidance and Vulnerabilities Analysis
  • Law Society of New South Wales AML/CTF Hub
  • Information on AUSTRAC’s AML/CTF Reform
  • Norton Rose Fulbright’s Tranche 2 and AML/CTF Reforms Hub

Visit our website and get in touch to learn more – we would love to hear from you.


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