Chapter of the Year 2018

Australasian Chapter


Upcoming Australasian Chapter learning events will be announced soon.

Australasian Chapter received the ACAMS Chapter of the Year Award – 2018. This is significant for a number of reasons – one of which is that this is the first time the ACAMS Chapter of the Year has been awarded to a chapter outside of North America. Aub Chapman, Co-Chair accepted the award as part of a wider awards ceremony during the ACAMS conference in Las Vegas in October 2018. It was very pleasing that Kylie Oliver (Australasian Chapter board member and one of the two finalists in ACAMS Professional of the Year Award) and two chapter members from New Zealand were also in attendance at the Las Vegas conference.

There are a number of criteria that the ACAMS management team look at when deciding ACAMS Chapter of the year, and quite some thought and discussion go into it before a deserving winner is announced.  Below are some of the key decision points (there are others)

  • Positive impact on local financial crime community
  • Diversity of membership
  • The quality and frequency of chapter events
  • Board are active and engaged members of ACAMS
  • Aligned with ACAMS strategy and goals
  • Proactive and passionate
  • Awareness in the market place (large new growth of ACAMS members, driven in large part to Chapter activity)

ACAMS management team also took into account the fact that ACAMS is less known in our region, and the extra work and outreach that is required to spread the message. The award reflected our efforts over a number of years to support and promote ACAMS – not just in the last 12 months. This reflects well not only on the current chapter board members but also a number of those who were board members over the past few years.

The ACAMS Australasian Chapter was formally established in late 2007 with the main objective being to support ACAMS in its mission to advance the professional knowledge, skills and experience of those dedicated to the prevention and detection of money laundering. A second and equally important objective is to provide local AML professionals with a support network of like-minded persons and to deliver member events throughout the region.

The Chapter will assist ACAMS with the development of a CAMS elective sub-certification examination module that tests knowledge and understanding of Australia’s and New Zealand’s Anti-Money Laundering legislative regimes.

The Chapter covers the Australasian region which includes:

  • Australia
  • New Zealand
  • Papua New Guinea
  • Pacific Islands


In 2013 the Australasian Chapter Board of ACAMS resolved to implement a moratorium on chapter membership fees. The effect of this decision is to automatically extend chapter membership to all members of ACAMS who reside in the Australasian region.

What this means is that you will be automatically granted Australasian chapter membership when you join or renew your ACAMS membership at no extra cost. Membership to the chapter will be synchronised with the same timeframe as your ACAMS membership.

For inquiries in relation to ACAMS membership, please email or for Chapter membership, please contact Rodney Willis at or Phil O’Connell at

Upcoming Australasian Chapter learning events will be announced soon.

Upcoming Events

An examination of the new Anti-Bribery & Corruption legislation – what it means for your organisation

The Government has reintroduced the Crimes Legislation Amendment (Combatting Corporate Crime) Bill 2019 (Cth) (the ‘Bill’) to the Senate for a second time. If the Bill is passed successfully, its implementation will bring Australia’s bribery framework up to a standard close to the requirements of the UK and the US.

Once enacted, significant adjustments will be required to your policies and procedures and strategic decisions may need to be made early to ensure compliance within the time frames given. What do you need to know and how can you anticipate and prepare for the changes?

Join us for a virtual event with Julian Hunn so that you are up to date with the anticipated changes and are equipped to strategically address them in your compliance and risk framework.

Todd Harland
Co-Programming Director (Brisbane)
ACAMS Australasian Chapter

Guest Speaker

Julian Hunn

Julian Hunn
Director – Risk Advisory

Julian is a Financial Crime Risk professional with over 20 years of compliance experience and is currently a Director contracting to Deloitte Risk Advisory. Much of his time has been spent abroad working in Europe, Asia and the Middle East focusing on financial crime prevention strategies and operations. Julian has held senior compliance roles at HSBC, Merrill Lynch, Standard Chartered Bank, Jefferies International and Westpac. He holds a MBA from the University of Queensland and a Criminal Justice degree from Griffith University. Julian is a member and Director of the GRC Institute, AICD member, working group member of ACAMS and a Fellow of the International Compliance Association.

Past Events

KYC, CDD and Digital Identity in a digital era

Our first virtual event for 2020

As members will be aware, the Chapter Board has commenced a Chapter-wide program of monthly virtual events in an endeavour to continue to provide a program of education and training events.

The first of these was a very successful event held on Tuesday, 21 April with our Co-Programming Director (Sydney), Irina Samoylova joining with guest speaker, Tony Fitzgibbon (CEO, Data Zoo) to discuss one of the most pressing issues facing AML/CTF practitioners in these very challenging times.  

KYC Electronic Verification (EV)

More than ever, companies now need to be vigilant with KYC and CDD. With the world going online, there has been an increase in the demand for electronic identity verification. In these unprecedented times, people need reliable and trustworthy client onboarding and customer due diligence solutions.

It was a great discussion with Tony Fitzgibbon, with such an urgent topic, that generated many follow up questions from an audience of over 400 attendees from 55 countries across Australasia, APAC, MENA, Eastern and Western Europe, Africa, North and South America, and Caribbean.  

In this session, Tony Fitzgibbon provided us with a wide ranging presentation covering a number of topics, including:

Digital identity management and the changing landscape within the APAC region and globally;

  • EV: 2 Safe Harbours: What is digital ID: concepts, confusions
  • Biometrics regulatory requirement vs. video or photo taking
  • Importance of reliable data sources global
  • Legal obligations vs. pure solution

Verification of Australia/New Zealand citizens vs. International

  • Credit (Equifax, Transunion, Experian)
  • ID verification – facial recognition
  • Detailed break down by jurisdiction.
  • Challenges and lessons learned.
  • Importance of reliable sources overall.

The developments from COVID-19 and what is now the focus of attention; and
The importance of a seamless digital experience and how protecting your customers’ personal information is vital.

Tony gave us some great insights on a number of topics, including critical challenges around reliable data, regulatory pressure and expectations to fulfil CDD requirements in the digital era, especially in the face of COVID-19 pandemic. Tony also raised the need for 2 factor verification and issues with verifying foreign passports, etc.

Informative discussion on best practices, challenges, the lessons learned across many jurisdictions. There were participation with over 30 questions submitted by attendees, and meaningful insights.
Tony left us with a number of critical concerns to consider, including:

  • Differences in global regulatory requirements standardsCOVID-19 lockdown impact: fraud, data security;
  • Accountability model for KYC outsource reliance;
  • Third Party reliance; and
  • Governance/management oversight and outsourcing reliability.

His parting thoughts on “Privacy by Design” – The customer being in control of who can use their personal data, was a great way to wrap up our first Chapter-wide virtual event for 2020.

Capital Markets Financial Crime Prevention: Identifying and Monitoring Complex Schemes

The ACAMS Australasian Chapter hosted an event, sponsored by Macquarie Group on “Capital Markets Financial Crime Prevention: Identifying and Monitoring Complex Schemes”. Discussion covered how the securities and capital markets sector is susceptible to an array of financial crime and participate in engaging with markets experts as they share new developments in domestic and international regulatory space, arising risks in products and technology, and methods to identify and prevent financial crime.

Capital markets are hardly ever viewed as susceptible to money laundering, terrorist financing or other financial crime. The abuse of financial markets products and services through investment banks, is a topic that is hardly raised. Such cases are very substantial, based on the complexities of global schemes, ranging from Ponzi schemes (e.g. Madoff), to Deutsche Bank’s “mirror trades” case, Goldman Sachs’ connection to the 1MDB scandal, or “pump and dump” white collar crimes, efforts fall short to drive industry change by identifying and preventing billions of dollar in criminal activity.

The lack of understanding, due to complexity of the products and vulnerability of the market, has not been widely acknowledged. Deutsche Bank’s cross-border netting “mirror” trading has been an eye-opening example of money laundering (ML), fraud, market manipulation and other predicate offences. Financial Action Task Force (FATF)’s Mutual Evaluation Report indicated that law enforcement in Australia focused more on the predicate offences and disruption of criminal activity instead of pursuing convictions of money laundering offences and disrupting ML networks.

Excellent input from Anatoly Kirievsky, Philip Charlton, Adam Parks and Matthew Field on vulnerabilities of capital markets and wholesale banking, the risks of the eco-system and how to unravel the complexity of product structures and clients with manual and automated tools, such as entity resolution, merging trade surveillance.

Risk Management in International Fund Transfers and Payments: Navigating Regulatory Enforcement

Our first event for 2020 was a panel of experts discussing the complexities of cross border and pre-paid card payment systems. The audience heard from Neil Browne, Julian Hunn, Ramanathan Karuppiah and Irina Samoylova Kunces. With the recent AUSTRAC enforcement cases relating to Westpac and Compass Global Markets as a back-drop, the panel examined the need for a thorough understanding of risk and controls relating to cross border payments, as well as the implications for de-risking which can result in simply risk-shifting and less visibility rather than effective risk management. IT matters continue to be a key player in the AML/CTF risk management world and with disparate actors in large organisations (business lines, IT, Operational Risk, FinCrime Ops etc.) there is a need for a common language, or an understanding of the language in order to reduce the risk of mis-interpretation of a problem. The concept of a central point of responsibility within all organisations, as is seen in Europe, was raised as a potential next step for the AML/CTF regulator.

The need for organisations of all sizes to have a risk framework for the escalation and management of breaches was discussed and the limitations of that within small organisations where English is not the first language. This was raised about how could a business owner who does not understand English, be expected to develop and implement an effective program.

The panel also discussed the risks associated with pre-paid and reloadable cards. The 2017 AUSTRAC report relating to payments was highlighted along with a suggestion that the regulator should place a limit to the amount able to be loaded to a stored value card. Again this would be following the European model, who with the latest round of Directives were seen as “light years” ahead of the Australian markets.

We would like to formally thank our gracious hosts, Michelle Milts, Karyn Mauerhan and the team at Suncorp for making everyone welcome and hosting a fantastic event.

Risk Management in International Fund Transfers and Payments: Navigating Regulatory Enforcement

Cross border transactions are under increasing regulatory scrutiny by the global regulators in light of recent enforcement actions across international banks, remittance companies and other regulated entities. Domestic and international transfers and payment services have been abused by the criminal syndicates with trillion dollars laundered. On January 30th, the ACAMS Australasian Chapter conducted its event in Sydney and Melbourne.

Criminal organisations operate as businesses. In order to disguise their origin and illicit nature of their operations, and avoid detection by the banks, they set up multiple websites and obtain multiple merchant accounts. This exploitation of the fund transfer and payments system puts acquiring and processing banks and payment facilitators at risk. For every site that is terminated as the result of illegal activity, dozens more continue their dual-purpose business model, with new criminals entering the payments chain every day.

Independent Sales Organisations (ISOs), Payment Service Providers (PSPs), and payment facilitators at risk. Seemingly low-risk merchants and online retailers selling toys and games may sell illegal drugs, counterfeit goods, weapons, violent content worldwide. The complexity of cross-border threats to payments service providers is astounding, and the consequences for violations can be devastating. It is imperative to have a fit for purpose framework, enabled by technology, could help organisations to stay compliant and prevent the criminal proceeds being laundered.

By working together, criminals can bypass laws, find the loopholes in regulatory requirements more easily and provide supply more efficiently. The complexity of cross-border threats to payments service providers leads to devastating consequences.

Insightful discussion from guest speakers include Amanda Wood, Jonathan Hatch and Aub Chapman in Sydney and Eric Frost and Ramanathan Karuppiah in Melbourne as to how the fund transfer and payment sector is susceptible to financial crime, and how organisations can set up a framework to identify and prevent financial crime.

Law Enforcement Lessons Learned
Rooftop Event

The NSW Police Force are actively targeting money laundering and continually seizing drugs, firearms and significant amounts of cash. Their dedicated work aims to bring crime syndicates down in Australia and abroad. On December 5th, the ACAMS Australasian Chapter hosted a Year End event with Detective Sergeant Warren Lysaght, sponsored by Randstadt, as he shared insights into high profile cases, as well as discussed advancements in money laundering investigations.

Insightful presentation on the Strike Force BUGAM investigation into a controller of a transnational money laundering (ML) syndicate. Our guest speaker provided us a breakdown into mule recruiting, operations schemes of transnational ML syndicates, and how the Strike Force gathered evidence to take down the criminal activity. The challenging investigation showed how ‘following the money’ led to unveiling a relatively unknown organised crime group, the disruption of a ML syndicate, seizures of drugs, guns and money, cuckoo smurfing and was featured as part of the amended statement of claim by AUSTRAC in the civil penalty case against the Commonwealth Bank of Australia. This was a good example of public-private partnership.

Financial Action Task Force (FATF)’s Mutual Evaluation Report indicated that law enforcement in Australia focused more on the predicate offences and disruption of criminal activity instead of pursuing convictions of money laundering offences and disrupting ML networks.

Revisiting The Panama Papers, 3 years on – What has changed?

The publication of The Panama Papers in 2016 was a watershed event for financial crime, a deep expose of the market for offshore secrecy services. Trust and company secretariat providers can be misused along with the services of lawyers, accountants and other professionals. Those disclosures specifically came to bear on offshore commercial structures and tax havens, used to hide assets, and the role of lawyers in the establishment and conduct of those structures.

Repercussions from the Panama Papers led directly to AML/CFT coverage for lawyers and Phase 2 professionals being accelerated in New Zealand, after the John Shewan Report.

At a global level, the International Bar Association and the Organisation for Economic Co-operation and Development set up a joint Taskforce to look at the role and responsibilities of lawyers in this area. The joint IBA and OECD Report was published in May 2019.

These issues remain current, with the FATF publishing Guidance on Beneficial Ownership for Legal Persons in October 2019.

Two legal experts, including Robert Wyld of Australia (principal author of the IBA Report) and Gary Hughes (NZ) will lead this special breakfast seminar discussion.

Guest Speakers

Robert Wyld Robert Wyld, Consultant, Johnson Winter & Slattery (Sydney), former Co-Chair of the IBA anti-corruption division.

Gary Hughes Gary Hughes, Barrister, Akarana Chambers (Auckland), ACAMS Australasian Chapter Advisory Board, NZ Country Officer for the IBA Anti-Corruption Division.

2019 Year In Review and the Outlook into 2020
Networking Rooftop Event

On November 14th, the ACAMS Australasian Chapter hosted a rooftop event on 2019 Year in Review and the Outlook into 2020 with guest speakers, Lesley Symons and Ben Buckingham. It’s been a challenging and volatile year for the financial industry in Australia. Some of the largest financial institutions and its executives have been on a rollercoaster ride since the Banking Royal Commission review. The financial scandals, enhanced supervision, regulatory enforcement, self-disclosures among the reporting entities and the FATF Mutual Evaluation are influencing regulatory landscape.

The panel discussed on the Design and Distribution Obligations and Product Intervention Powers legislation, their impact on the Risk Assessment framework, the BEAR regime on accountable person, including compliance and Financial Crime Risk Management, and how it impacts an organisation’s risk tolerance and conduct and culture.

“Phase 1.5” in Australia’s AML/CTF reforms introduced into the parliament in October offered additional challenges that will require a significant assessment, standardisation and a robust risk framework. The intent of the Bill is to introduce ways to strengthen the regime and improve the personal and transactional information sharing, in order to support cooperation and collaboration to detect, deter and disrupt money laundering, terrorism financing, and other serious crimes.

On face value, replacing Section 38 with 37A and 37B and reliance on customer due diligence performed by the third party is estimated to save $3M in compliance costs and regulatory savings. Guests speakers weighed in on whether it has been an easy win or will it potentially introduce Correspondent Banking due diligence “burden” and accountability to keep each other in check.

AUSTRAC Outreach Event

The ACAMS Australasian Chapter held an AUSTRAC Outreach event in Sydney on December 10, 2019. It was a great way to close out the Chapter program for 2019 with a message from AUSTRAC and what it truly means for the industry. It has been a very busy year for the private and public side. Mark Crawley provided an update on AUSTRAC’s initiatives in 2019 and the areas of focus and collaboration for 2020 and beyond. From the base of an adequate and commensurate risk assessment, aligned to a bespoke business profile risk, to the governance and how it impacts the business. Important point on raising the bar and developments around AML/CTF advisors. The reliance on the expertise and adequate knowledge and connectivity is extremely important for the safety of the ecosystem. The onus and responsibility is with the reporting entity.

Conduct and Culture in the Post Royal Commission Era: Impact on BEAR Regime

On October 17, ACAMS Australasian Chapter hosted a first “proof of concept” multi-location live-streaming event between Sydney and Melbourne on Conduct and Culture Post Royal Commission Era: Impact on BEAR Regime. It was an informative discussion with Anatoly Kirievsky, Lesley Symons, Justin O’Brien, Guy Boyd, Willem Torren and Pamela Hanrahan, moderated by Co-Programming Directors, Irina Samoylova Kunces and Kylie Oliver.

Organisational complexity and diffused responsibility have been at the heart of many of the issues that have damaged the standing of the banking industry in recent years. Organisational culture and awareness of financial crime is one of the key challenges of an effective Financial Crime Risk Management (FCRM) among most organisations.

Process failures or poor decision-making have been the result of a lack of clear accountability for ensuring a product works as it should, a risk is fully understood, or that a system delivers what was intended. The Royal Commission into Financial Services and APRA’s Prudential Inquiry into CBA has highlighted the increasing focus on accountability in Australia. The Banking Executive Accountability Regime (BEAR) is primarily focused on prudential matters. However, the level of attention on conduct and culture, driving organisational compliance in the current environment, questions the boundaries between FCRM, conduct and culture.

Firms will need to fully appreciate how regulators views misconduct. Whilst individual accountability is a relatively easy concept to understand, in practice pinpointing the accountable owner in any situation has become harder. The clarity of accountabilities, the clear obligations, and the potential sanctions, will inevitably draw attention on all concerned in ensuring accountabilities are understood, and issues that need attention are promptly addressed. It is a problem when you are trying to find a few identifiable people that will take responsibility for various activities conducted at a senior level.

New Zealand FIU Conference

ACAMS teamed up with the New Zealand Police Financial Intelligence for the seventh year to host the 2019 Anti-Money Laundering & Countering the Financing of Terrorism Conference on the 8th and 9th October at the Museum of New Zealand Te Papa Tongarewa, Wellington, New Zealand.

The theme of this year’s conference was New Zealand: AML/CFT’s first decade – Embedding and Adding Value, with presentations focused on developments worldwide into closer working relationships with reporting entities (now including professional advisers), law enforcement and their many partner agencies; that highlight how all parties contribute to the best possible outcome.

The keynote speaker was Unn Hege Sorenson, who lead the team investigating Anders Breivik’s financial activities, related to the terror attacks in Oslo and Utoya on 22 July 2011. Her insights resonated with the New Zealand audience following the recent terrorist attack in Christchurch.

The Conference was attended by roughly 450 participants; including representatives from AML/CFT reporting entities, Police, regulators and other public sector agencies. The programme brought together domestic and international speakers from government and the private sector, and continues to be the largest AML event of its kind in New Zealand.

Practical Advice – Lessons from Enforcement Actions and Breaches

With financial crime enforcement slated to increase in New Zealand, the Australasian Chapter hosted a session on lessons from enforcement actions and breaches. Participants gained insights from an experienced panel of local and international experts who have guided reporting entities through major enforcement actions across the globe.

Aub Chapman, Co-Chair ACAMS Australasian Chapter and Nick Griffith, Regional Director – Business Development, Australasia ACAMS started the evening with an overview of ACAMS globally and across the Australasian region. Nick introduced his team, based out of Australia and gave an overview of the extra support the full time staff will be offering the Australasian chapter. We then moved into the introduction of ACAMS certification programmes, the highlight being the introduction of ACAMS new certification, Certified Global Sanctions Specialist (CGSS) and the upcoming advanced certification CAMS – Risk Management. Dr Scott Grob, AML Director – APAC, ACAMS was also in attendance and discussed developments in ACAMS across the Asia-Pacific region, covering upcoming conferences and upcoming certification sessions.

Our conversation then moved into our panel discussion, moderated by Chris Faherty, Co-Programming Director (New Zealand). Panel speakers included: Martin Dilly, Phil O’Connell, Irina Samoylova, Scott Grob, Aub Chapman. The panel covered what constitutes a breach and how you can mitigate the risk. Phil O’Connell, GM Regulatory Affairs – Skycity, spoke about the importance of going to the regulator with an action plan, drawing on his own experiences. Aub Chapman weighed in with the significance of developing playbook to cover a range of scenarios that could potentially occur within your reporting entity.

Martin Dilly and Aub Chapman lead the closing address, focusing on the key takeaways from the session: being proactive, anticipating board and executive concerns, developing playbook to manage situations and the role networking and knowledge sharing plays in strengthening an AML regime.

AUSTRAC Outreach Event

On Thursday 26 September 2019, our Chapter held its first ever event in Perth. This event marked the start of our expansion of the chapter-wide events program to now include Perth.  Feedback from many of the attendees suggests that there is keen interest in the chapter running regular events in Perth and we are now working towards a program that will support that need. 

Toby Noble (Chapter Treasurer) and Aub Chapman (Chapter Co-Chair) represented the ACAMS Australasian Chapter at this event which was generously hosted by Teachers Mutual Bank (TMB) and we really appreciated the willingness of TMB and a number of the bank’s staff in helping with organising this event.     

This event was also our first ACAMS-AUSTRAC joint event and we were treated to a very engaging presentation by Mark Crawley from AUSTRAC.  Mark, who is Manager Regulatory Operations, highlighted AUSTRAC’s concern with the level of compliance by many reporting entities, particularly in relation to governance and oversight by boards and senior management.  AUSTRAC’s on-site compliance assessments suggest that the lessons arising from the CBA and Tabcorp enforcement actions should be taken into account when reporting entities review and update their ML/TF risk assessments and AML/CTF Programs.  Mark emphasised the need for reporting entities to undertake reviews when new products and services are introduced.

Mark then moved on to highlight areas where many reporting entities are failing to cover all ML/TF risks resulting in the ML/TF risk assessment and AML/CTF program being deficient.
Turning to AUSTRAC’s analysis of the 2018 Annual Compliance Reports, the audience was surprised by the results that Mark shared, including the number of reporting entities that failed to submit the annual compliance report.  Mark indicated that AUSTRAC has already engaged with 400 reporting entities regarding information provided in their latest annual compliance reports.

Mark spoke on the importance of Advisors in assisting reporting entities in developing ML/TF risk assessments and AML/CTF programs, delivering AML Risk Awareness training and in undertaking Independent Reviews.  AUSTRAC is concerned at the quality of advice being provided by a number of those providing Advisor services to reporting entities. To assist AUSTRAC is developing a clearer framework of what is expected and a number of Advisors were recently invited by AUSTRAC for one-on-one meetings at which Advisors shared their experiences.

For each of these 4 key topics, Mark also highlighted key points that will be included in Fact Sheets that AUSTRAC will be publishing very shortly.  The audience were also treated to an advanced viewing of 4 short videos that AUSTRAC will be posting on its website to reinforce the content in the fact sheets.

Following Mark’s presentation and a short Q & A session, the attendees then joined Mark and the Chapter board members for an informal networking session during which there were some very positive feedback on the event in general and more particularly, Mark’s presentation.  

The Cybercrime Dark Market Economy – why it is no longer “crime as a business” but “crime as an economy or platform capitalism”.

We will discuss how this continually evolving sophisticated market place has, and will continue to drive criminal economies globally. Understand how much money is being made, how much they convert into assets such as a property, how much crime is being supported and why it might go from the Dark Web to the Invisible Web.

Guest Speaker

Brian Hay APM
Brian Hay APM has a rare blend of cyber security skills and business attributes.  Long considered a Thought Leader in the world of Cyber Security he learned his craft not from the technical demands of the industry but rather by focusing on the activities of organised crime and cyber criminals.

Brian was Detective Superintendent at Queensland Police, where he served 35 years. Since 2004, he has worked extensively in the area of financial, identity and cybercrime.  He was Commander of the Queensland Police Fraud & Cyber Crime Group, Chair of the Australia New Zealand Police Advisory Agency’s eCrime Working Group, a pivotal driver of the Australian Cybercrime Online Reporting Network, and member of the Federal Attorney-General’s National Cybercrime Working Group.

How the Changing Sanctions Landscape has Impacted the Financial Services Sector

Increasing complexity, regulatory rigour, and the inconsistent nature of global regimes are raising the bar for sanctions compliance. On September 11 (Sydney) and September 12 (Melbourne) ACAMS Australasian Chapter and Refinitiv hosted panel discussions on how on how the changing sanctions landscape impacted financial services. Guest speakers included Phillip Malcolm, Gail Carter, Manmohan Toshniwal, and Alice Saveneh-Murray on how increasing complexity of global sanction policies make it extremely difficult to navigate the landscape, as demonstrated by regulatory scrutiny, Consent Orders and hefty multi-billion dollar fines.

The panel covered how sanctions fit into the AML eco-system, how risk assessment and KYC are critical to understand the client, their ultimate beneficial owners/controllers not to violate sanctions. Different sanctions types affect organisations based on a business profile, products, services and client segmentation. Guest speakers discussed on challenges with automation of sanctions compliance, complexity of narrative sanctions, indirect and sectorial sanctions, and how training helps to mitigate these risks.

Developing Trends in Transaction Monitoring, Fraud Prevention and Trade Based Money Laundering

Our moderator, Nicholas McTaggart introduced our panel. Ben Buckingham from Identitii, and Shaun Mathieson from Quantexa explained to the audience how their technology is evolving the way data can be analysed, and how this can be of intelligence value to the community. They also spoke of how this can contribute to reporting and how they can build on efficiencies in our institutions and organisations. Identitii is providing demonstratable evidence for the regulator. Quantexa is providing context and assisting with detection and investigation, faster.

Dylan Ryan from ANZ tells us that large financial institutions are building data lakes – but the question is, now what? Especially when the data sit in silo situations. How does one make sense of it, or tie it together to make it useful and actionable? When an institution has silos, it’s easy for money mules to navigate safe harbour rules in identity takeover situations. In the data lake environment, it was identified that just one person had opened up 140 accounts. This was discovered, because the same password (or password logic) had been used for all 140 accounts. The data lake environment enabled a network analysis.

Discussion moved onto the evolution of how criminals are becoming sophisticated and using sophisticated products such as trade finance, correspondent banking, and possibly even undergoing the same training that we, as Financial Crime professionals, are undertaking. Yet, many of our institutions still use traditional and dated Transaction Monitoring systems that only look at account and customer ID level, rather than a holistic picture. This doesn’t allow the ability to identify or link cases in different products or different jurisdictions. The behaviours of criminals are multi-faceted and have evolved over time.

New technologies such as Blockchain are allowing us now to focus on time (of day), password patterns, systems of behaviour and the ability to measure the past but also understand what the path ahead looks like.

Large institutions are challenged when investigating complex scenarios. How much time do you allow for an investigation? How can this data be broken down and explained to a non-technical person, or a regulator?

An example we heard about, was from a case study where Identitii’s technology enabled their customer to analyse their invoice data and detect that the same invoice had been used in multiple situations, and was identified as invoice fraud. The technology was able to reconcile invoice, payment and settlement information.

In Fraud prevention, development of the Fraud system set up amongst peers is far more mature than the AML peer network due to restrictions in legislation and information sharing.  In the Fraud space, the detection of fraud can be known around the institutions in almost real time. Government initiatives such as the Fintel Alliance are challenging the way this is approached.

ACAMS Australasian Chapter – Sydney Event, Streaming Live to Brisbane

Future of Tranche Two

Two major reviews of Australia’s anti-money laundering and counter terrorism financing regime released in 2015 and 2016, identified continuing weaknesses in the current framework and identified use of professionals to facilitate money laundering. One of these reasons is the lack of coverage for a range of non-financial businesses and professions that can be exploited to launder illicit funds and support terrorism. The 2016 statutory review proposed 84 recommendations, with r. 4.6–4.10 referring to ‘developing options for bringing the remaining Designated Non-Financial Businesses and Professions (DNFBPs) within the scheme’. The OECD Phase 4 Report from 2017 recommended Australia and more recently, the International Monetary Fund’s (IMF) Financial Stability Action Plan pointed out that the failure to regulate DNFBPs could fuel a range of systemic risks in Australia and recommended to address the risk that the real estate sector could be used to launder the proceeds of foreign bribery. Consultations on laws to extend the regime to include them began in 2007, but this was later put on hold and a Bill is yet to eventuate a decade later.

Australia is viewed as the money laundering ‘washing machine’ for real estate fraud. Limited transparency into complicated structures, and identifying Ultimate Beneficial Owners (UBOs), law enforcement ties to drugs, human trafficking and other illicit proceeds to supplied cash deposits for real estate purchases and complex account set-ups. In a last few years, a growing economy and absence of AML/CTF regulations has made the Australian real estate an attractive destination for money laundering criminals as a channel to launder illicit funds and help in conceal large sums of money very easily. According to AUSTRAC, in the 2015/16 financial year, an estimated $1 billion in suspicious transactions were made by investors from China in the Australian property market. Overall, there has been a growing concern around lack of AML/CTF regulation of professional services, due to investigation cases that identified sophisticated AML/CTF criminal syndicates created by lawyers and accountants. In Australia and globally, the use of legal practitioners and other ‘gatekeepers’ to launder illicit funds have been highlighted through increasing complexity and sophistication of money laundering schemes.

Panel Discussion:

The panel will discuss AML/CTF growing concerns in Australia around lack of regulation of Tranche 2, and growing exploitation of the system by criminals. The panel will cover current trends and challenges with implementation and enforcement of the regulation and what impact the delay of Tranche 2 may have on FATF Mutual Evaluation of 2019-2020.


Irina Samoylova Kunces, CAMS – Co-Programming Director (Sydney), ACAMS Australasian Chapter

Panel Speakers:

Jeremy Moller
Risk Advisor, Norton Rose Fulbright Australia

He has 10 years’ experience working in Australia, the United Kingdom and New Zealand as a lawyer specialising in anti-money laundering, international sanctions and anti-bribery and corruption.

Beginning his career in New Zealand during the global financial crisis, Jeremy advised financial institutions on insolvency disputes and enforcement action. Subsequently he has worked in regulatory compliance roles advising entities both internally and externally on their approach to financial crime, and also third party risk management, business continuity and conflicts of interest.

Working with a team of multi-disciplinary experts within Norton Rose Fulbright’s Risk Advisory practice, Jeremy specialises in assisting clients across sectors in relation to financial crime, with a particular focus on anti-money laundering and international sanctions. He is experienced in dealing with a range of regulators both in Australia and overseas in relation to financial crime. His work includes leading, implementing and reviewing financial crime programmes, such as conducting business wide risk assessments, as well as advising on litigation arising out of regulatory investigations.

Jeremy recognises the importance of both improving customer experience and ensuring compliance. Having led in a risk and compliance function for an international law firm, he has a unique understanding of the synergies between both legal compliance and operational risk management and provides clients with a holistic and commercial approach to regulatory issues.

Jeremy sits on the Ethics Committee of the New South Wales Law Society. He has a keen interest in governance and assists a number of not-for-profit entities with their legal and regulatory compliance.

Neil Jeans
Principal, Initialism

Neil has a unique background in financial crime risk management, spanning 25 years. This includes working within Law Enforcement agencies investigating financial crime, including domestic and international fraud and money laundering, and as a Financial Services Regulator (UK FSA) developing AML regulation and supervision techniques.

He has also worked at senior levels managing AML, Sanctions and Anti-Bribery compliance across Europe, the US, Latin America, Asia and Australia within three major European financial services companies and one of the major Australian banks.

Neil was a member of the Board of the UK’s Joint Money Laundering Steering Group (JMLSG) which sets the AML/CTF standards for all regulated businesses in the UK, and was responsible for designing the Risk Based Approach to AML/CTF adopted as part of the Guidance Notes.

Neil has extensive experience in designing and implementing policy and controls to address AML/CTF compliance and since August 2012 has working as an independent consultant advising financial institutions in Australia and globally on AML/CTF matters.

In addition, Neil is member of the faculty and lectures as part of the International Compliance Association (ICA) Diploma of Applied Anti Money Laundering and Counter Terrorism Management, is a founding member of the SWIFT Sanction Advisory Group and has regularly attended the Private Sector Expert forum of the Financial Action Task Force (FATF).

He was founding Joint-Chair of the Association of Certified Anti-Money Laundering Specialists (ACAMS) Australasian Chapter, and was a member of the UK Joint Money Laundering Steering Group (JMLSG) Board between 2003 and 2006.

Neil is the co-founder of a RegTech company called AML Accelerate that provides AML/CTF Programs and Risk Assessments to small and medium sized Reporting Entities in Australia and globally.

In 2017 Neil was appointed by the Australian government as their ‘expert witness’ in the civil claim against CBA for AML/CTF breaches, which resulted in CBA paying a settlement of $700 million in 2018.

Aub Chapman
Co-Chair, ACAMS Australasian Chapter

Prior to his retirement, Mr. Chapman was a career banker with over 42 years of professional experience. In his last role at Westpac Banking Corporation, he was responsible for managing a number of functions including Group Fraud Control, Physical Security, Business Continuity Services, Cash and ATM Services as well as managing the group’s compliance with AML/CTF legislation. Since his retirement, Mr. Chapman has been consulting in both the public and private sectors, not only in Australia, but also internationally. He specializes in controls against financial crime and management of cash services. His international experience includes assignments for the United Nations, the Asian Development Bank, The Eurasian Group on Money Laundering (on behalf of the FSVC), Bank Negara Malaysia, Institut Bank-Bank Malaysia and the Labuan Offshore Financial Services Authority. He has been a guest speaker at a number of international AML/CTF conferences and international conferences associated with the cash services industry.


  • Norton Rose Fulbright Australia
  • Flight Centre

Industry Common Challenges in Building an Effective AML/CTF Risk Assessment Program

Risk Assessment is a cornerstone of an institution’s Financial Crime Compliance Program. It effectively assess and drive improvements in Financial Crime Risk Management. Risk Assessment is a bespoke exercise that produces a program applicable to the specific institution, based on their customer types, products and services offering, channels and jurisdictions they operate.

Neil Jeans, Anthony Quinn and Nicholas McTaggart discussed common trends and challenges within the banking and broader financial Industry, including understanding vulnerabilities and building adequate control capabilities. The Panel discussed how poor methodology or “tick the box” exercise could expose organisations to portfolio risk, control deficiencies and potential regulatory fines.

Discussion around rising risks and tech capabilities adoption echoes AUSTRAC message on its priorities for 2019. Complexity of client relationships and products, real-time payments, open banking, and new digital channels, require a robust holistic risk assessment to help the organisation to make informed decisions.

Follow The Money: Challenges of Beneficial Ownership Unwrapping and Transparency of Money Flow

Criminals around the globe are using various methods to conceal their identity and hide their assets and holdings across not only traditional banking accounts, but commercial and private real estate, investments, and in recent years digital assets, structured e-commerce and shared economies schemes.

We had an exceptional panel, representing Risk, Data, Business and Law Enforcement with over 25 years, provided great insights on vulnerabilities around the transparency of beneficial ownership and true controllership, and how it affects the financial system.

Only a holistic, end-to-end process, and collaboration of all parties will help provide meaningful analysis to prevent the crime.

How do we change the culture and incentives to ensure the business truly understands the risk? Accountability is a key driver, financial crime compliance officers need to become trusted advisors to the frontline, that will be responsible and accountable.

Prepaid Cards Vulnerabilities and Framework For Securing Digital Payments

AUSTRAC Compliance Report and Modern Slavery Risks, Rights and Responsibilities

It was great to see so many familiar faces and lots of new members from Melbourne’s Financial Crime community at our first event for 2019, hosted by Jeremy Allan, Director of KPMG Forensic’s Financial Crime Practice in Melbourne.

Dr Nicholas Newman, National Manager Regulatory Operations AUSTRAC, started the evening with details about the changes to AUSTRAC’s Compliance Report and expectations. Reporting Entities were reminded of the 31 March 2019 deadline and we were all encouraged to provide feedback on the new format. The Compliance Report is a great way to understand trends and challenges and provides insights to future areas of focus. AUSTRAC is doing a great job in getting out and talking with industry and have been a great supporter of ACAMS events over the last year.

Our conversation then shifted gears as Mr Richard Boele, Partner, KPMG, Human Rights and Social Impact Services discussed Modern Slavery, Risks, Rights and Responsibilities. Following on from the recently survey conducted by KPMG on behalf of the Australian Council of Superannuation Investors, Richard shared real examples, happening in plain sight in Australia. In the context of Australia’s Commonwealth (and NSW State) Modern Slavery legislation, Richard touched on high-risk factors, business models, categories, geographies and sectors and actions taken to address modern slavery risks and assessing the effectiveness of action.

Jeremy Allan led questions and discussions, focusing on the convergence of Money Laundering, Modern Slavery, reputational risk, raising of SMRs and potential trends and insights before we enjoyed the great view from KPMG’s office and networking with some familiar and new faces.

Preparation for the 2019 AUSTRAC Annual Compliance Report

Our first gathering for the year was held at Flight Centre on 28 February with the kind assistance of Julian HUNN and his team. With the Annual Compliance Report due in a matter of weeks (31 March) we were pleased to have AUSTRAC attend to deliver some timely information. Gemma HOLLIDAY (Compliance Division) and Michael DRUERY (Intelligence Division) were warmly welcomed by an audience of about 40 AML/CTF professionals from a wide range of reporting entities which included banking & finance, superannuation, remittance services, consulting firms and payment system providers.

To set the scene, Gemma spoke about the history of the Annual Compliance Report and the need for it to be redeveloped to be more meaningful for both the regulator and industry. It was recognised that the past decade of reporting was far from effective and provided very little benefit.

The new Compliance Report was redesigned in collaboration with industry and now asks participants to ‘paint the picture’ of their business.  It’s a move away from ‘technical compliance’ assessment to more of a ‘how do you comply’ questioning format.

The findings of this year’s Report will go to the Compliance Triage team for assessment and help the process of intelligence driven compliance. It is envisaged that the analysis of the data will help inform AUSTRAC as to where to direct their compliance activities. For accurate analysis to occur, it obviously relies on reporting entities to provide honest and accurate information. Gemma said that assistance can be obtained by calling the Contact Centre.

Michael spoke to the gathered throng about a number of intelligence related matters and was pleased to announce that the AUSTRAC database of reports had now crossed the one billion mark. In particular he discussed the Fintel Alliance where information is shared from the reporting entities to law enforcement agencies by de-personalising the information and sending it via secure encrypted communication platforms. He said that the process was critical to the arrest of two criminals in the first two weeks, and has continued to be a successful contributor to investigations.

The Fintel Alliance obviously looks across a wide range of crimes and at the moment there is a focus on Child Exploitation. He discussed the multi-agency task force, led by the AFP, created The Australian Centre to Counter Child Exploitation (ACCCE) which provides a consistent, holistic and coordinated response to counter the online exploitation of children in Australia.

Our Chapter would like to once again extend our gratitude to Julian HUNN and Flight Centre for kindly hosting this event.  We look forward to seeing you all at the next Brisbane based event.

AUSTRAC Preparedness Report

Panel Discussion


Donna Maloney – Financial Crime Compliance Senior Manager, Global Banking and Markets, HSBC Australia

Panel Speakers:

  • Carolyn Hanson – Director of Enterprise Risk, Compliance and Security at PayPal
  • Aub Chapman – Aub Chapman Consulting Services
  • Ian Webb – Deputy Head of Compliance at MUFG Bank

Event summary to follow.

Fighting 21st Century Problems: Anatomy of a Cyber-Attack

  1. Anatomy of a Cyber-Attack
    Presentation by Adi Ashkenazy
  2. Technology, Increasing Information Sharing and Anticipation of a Cyber-Attack
    Panel Discussion


  • Irina Samoylova Kunces, Co-Programming Director (Sydney), ACAMS Australasian Chapter
  • Harish Palagummi, Australia-based entrepreneur
  • Dr. Neil Roodin, Founder, enterpreneur, consultant, trainer and author
  • Adi Ashkenazy, VP, XM Cyber

Event summary to follow.

ACAMS “Year In Review” Sydney Networking Event


  • Janet McCarthy, Director, Regulatory Operations at AUSTRAC

Event summary to follow.

ACAMS Christmas Drinks Networking Event in Auckland

On 18 December 2018 we held an ACAMS members pre-Xmas networking session. This gave members an informal opportunity to compare financial crime notes with colleagues, tell war stories and unpack the year’s AML/CFT developments, in a good-natured, Yuletide, way. It was a nice event on a sunny bar balcony in Auckland with about 40-50 people dropping in and out to chat at different times of the evening.

Thanks to Martin Dilly AML and his newly launched business for sponsoring the food/nibbles.

Know Your Customer, Know Your Transaction: Understand Your Risk to Fight >> the Crime*


  • Irina Samoylova Kunces, Co-Programming Director (Sydney), ACAMS Australasian Chapter


  • Amber King, Head of AML/Global FCC Division, Morgan Stanley Australia
  • Susana Garcia, Head of Compliance, Societe Generale Securities Australia
  • Wendy Ward, Regional Head of AML Compliance, JAPA, American Express
  • Eric Frost, Co-Founder and CEO, Simple KYC
  • Nick Armstrong, Co-Founder and CEO of Identitii

Event summary to follow.

Enforcement Action: Lessons from New Zealand-Brisbane


  • Gary Hughes, Barrister

Event summary to follow.

ACAMS / New Zealand Police FIU 2018 Conference

On 3-4 October 2018 over 400 attendees, both veterans and rookies in the field of AML/CFT, assembled in New Zealand’s capital, Wellington, for the latest version of its premier annual financial crime conference.

This has been a leading joint venture conference organised by ACAMS together with the New Zealand Police Financial Intelligence Unit over successive years, and is now firmly established as a ‘must do’ event amongst financial crime-fighting and regulatory experts in the region.

As the 6th iteration of this public-private partnership conference, the 2018 event was an outstanding success for the ACAMS Australasian Chapter (recent recipient of the Chapter of the Year award for 2018). The event has grown year upon year, since ACAMS Australasian Chapter first joined forces with the NZ Police in 2013. Hard work by our volunteers and Chapter Directors has helped evolve the conference from a law enforcement seminar day that was primarily internally-focused up to 2013, into a major financial crime conference spanning 2 days and featuring impressive local and international keynote sessions.

Building a strong regional showcase event
ACAMS’ organisational role begins about a month after each successful annual conference ends, with early stage debriefing and date/venue selection for the next year. Working closely with the Head of the NZ FIU, the Chapter’s New Zealand Programming Director (Gary Hughes) and Membership Director (Phil O’Connell) then help to advance themes and content, locate and confirm speakers and topics, as well as handle all the incidental promotional planning and liaison to ensure ACAMS and the private sector community enjoy a headline presence at the event.

The conference itself has a number of unique strengths:

  • nearly a 50/50 split of law enforcement staff and regulated reporting entity attendees;
  • an equal mix of topics/sessions organised by the Police or sector regulators, and by ACAMS;
  • plenty of informal opportunities for compliance professionals to network and chat with the supervisors regulating their firm or, in some cases, the law enforcement officers who ultimately act upon the suspicious activity intelligence reports;
  • half-day workshops tailored to different levels of new or experienced compliance specialists, broken down into some sector-specific streams.

These features act as both a major drawcard to both New Zealander and Australian attendees, and help solidify ACAMS’ presence and demonstrable thought leadership in the region. Of the 410 attendees, around 25% this year were existing ACAMS members, with several more signing-up during the event. Gary Hughes on behalf of ACAMS acted as Co-chair/MC of the event, alongside Detective Sergeant Iain Chapman (National Manager of the Financial Crimes Group), whose fully- uniformed police presence reminded everyone from the outset that disrupting and breaking up crime is at the heart of what we do in this industry.

The thematic focus of this year’s conference was “New Zealand: a safe place to do business”. It served to emphasise how even these small remote isles are deeply connected in the modern globalised era, to financial crime and cybercrime trends from abroad. We know that New Zealand’s strong ranking as the easiest place in the world to do business relies on low levels of corruption, strong rule of law, and safe financial environments that enable stable competitive markets. But AML/CFT professionals can readily recognise that criminal elements are attracted towards business- friendly jurisdictions as much as legitimate commercial players. So there is always a need for vigilance, and the financial community can support these outcomes by facilitating a level-playing field where business partners can trust each other and deal in confidence with their regulators.

By detecting and preventing crime that can undermine New Zealand values, and the communities that AML/CFT professionals live and work in, they help make the country safer and well-regarded in the global village too.
The introductory ML/TF sessions run by each of New Zealand’s 3 Sector Supervisors (Reserve Bank of New Zealand, Department of Internal Affairs, and the Financial Markets Authority) were a valuable set of pre-conference event workshops. They catered to both intermediate and beginner compliance team members in various types of financial or gambling businesses, as well as Designated Non-Financial Business and Professions such as lawyers and accountants newly brought into our AML/CFT regime in 2018.

Top international line-up of speakers
The Australasian Chapter is rare if not unique amongst ACAMS chapters in that it covers 2 countries and 5 separate cities or major financial centres within the one Chapter Board, which certainly keeps the Chapter Directors on their toes! However, despite the administrative challenges of running a multi¬jurisdiction/multi-city chapter, this has a number of advantages when it comes to organising the conference. It gives us a deep talent pool of connections and potential speakers to tap into. Various ACAMS Directors and members from around the Asia-Pacific region have presented great sessions over the years at this event.

This year, 8 international speakers of very high quality presented. Three of them were from Australia, reflecting the strong ties with that nation – Sonja Marsic (Australian Government Solicitor), Prof. Louis de Koker (La Trobe University Law School) and Sean Harverson (AUSTRAC). They were joined by Hennie Verbeek-Kusters (Head of the Netherlands FIU), Stephen John (FINTRAC, Canada), Philip Hunkin (Head of the Cook Islands FIU), Nicholas McTaggart (Fiji) and Genevieve Noakes (TransferWise, Singapore).

The current chair of the Egmont Group, Ms Verbeek-Rusters delivered a stirring speech demystifying the Group’s work, and also answered audience questions with refreshing clarity and directness. Other keynote sessions on financial inclusion, FATF’s recent work on beneficial ownership, fraud and online scams, as well as people exploitation and motorcycle gang case studies were also well received. A showcase session dubbed “The AML Interview” focused on major enforcement action, including AUSTRAC’s ground-breaking AUD $700M prosecution of the CBA Bank.

Feedback has been very positive, with a lot of support to help the conference cement its place as one of the largest financial crime showcase events across Australia and New Zealand. As the international reach of the conference expands in future, overseas ACAMS’ members who may be tempted to visit these beautiful shores would be most welcome, and should keep a look out for October 2019 scheduling of the next iteration.

Money Laundering – Policing Perspective

It was a full house for AML professionals on 19 September, to hear about Policing Perspective from the NSW Money Laundering Unit. Hosted by ACAMS Enterprise Member, ANZ at their Pitt St office, we were fortunate to hear from Detective Inspector Stuart Sweeney and Detective Senior Constable Kylie Owen from NSW State Crime Command (SCC) on the agenda topics with case studies from closed cases ranging from 2014-2016.

Agenda for the evening: Money Laundering – Policing Perspective

  • Money Laundering Unit – details of the unit.
  • Simplifying the money laundering cycle.
  • Explanation of money laundering methods cuckoo smurfing – structuring
  • Brief case study cuckoo smurfing & structuring

Whilst touching on the agenda, consideration for familiarity with methodologies by gathered professionals meant discussed topics and case studies could be more indepth and detailed.

90% of the time, the SCC work closely with the AFP and other state and federal criminal agencies, financial institutions and regulators (such as AUSTRAC). This session concentrates primarily on drug related predicate offences, but exposes a range of crime types.

The Money Laundering Unit for NSW Police was created in 2014 as a restructure of the organised crime squad, with as little as 13 staff, aiming to disrupt or dismantle criminal syndicates. It is a trans-national environment, where international syndicates with controlling representatives are in Australia are here on instruction and moving money using tokens, involving clandestine bulk cash exchange.

They are able to manually source cases to begin investigating by hunting and reviewing material submitted by financial institutions as a one stop shop for investigations.

Why is Australia an attractive haven for criminal drug syndicates and money laundering?

Coke/Heroin per/kg: Street Value US Australia


Coke $34-39/kg $180-220/kg


Heroin $55-58/kg $280-296/kg


Meth $9-18.5/kg $80-150/kg

The majority (money) will be cycled back to the originating location.

There are four types of Syndicates:

  • Symbiotic
  • Specialised
  • Secretive
  • Sophisticated


ML is not involved in the predicate crime, it relies on the organised crime to acquire proceeds, and vice versa.


Qualified in financial services, eg a financial controller, with knowledge of or associated with relevant laws. Payment is received for skills and service provided to launder money.
The going rate for this is 3-5%.
If you’re paying 6-7%, you’re getting ripped off.
They are always continuing to develop new ways to avoid the authorities.


Use of prepaid phones, servers, and fictitious names.
Conduct clandestine exchanges.
Limited knowledge of the organisational structure of the syndicate or others involved in the syndicate.
No questions asked.
Use of tokens (such as the Australian five dollar note – methodology explained further in this summary)
Use of encrypted phone apps, such as WeChat, Whatsapp. This presents a challenge for law enforcement, as laws currently in place to protect privacy.


Planning is required and has an organised structure and hierarchy. Design of complex methods to layer and integrate money, and methods used to launder are limited only by imagination.
They are not limited to drugs and work with all illicit crime.

So how does it work?

An agreement/contract is decided.
The Organised Crime Group (OCG) and Money Laundering (ML) syndicate negotiate a contract (the ‘Controller’)
e.g. Money needs to get from Vietnam to Mexico, via Australia.
They agree on a percentage and the cost of business.
The Controller is independent of the crime group and the money recipient.
A ‘token’ is discussed and agreed upon.

The exchange takes place.
Money launderers will have the token. The OCG will receive the full token once the exchange has been made. This token serves as proof of exchange and is as valid as a receipt in this world. The contract is now active, and the ML syndicate is now responsible for the money that has been handed over, including having to wear the loss of the money should anything go wrong after this point. The system is based on trust.

What the ML Unit are seeing in their investigations:

  • Smurfs
  • Structuring
  • Bulk and Clandestine Exchanges
  • Tokens
  • Cuckoo Smurfing

The group was then taken through closed session of a series of case studies of operations and investigations that led to the conviction and incarceration of the targeted individuals.

Question time was hearty, and lively, there was not enough time to ask all questions from the audience. However, our speakers were happy to stick around to answer further questions.

During this time, we learnt just how vital reporting from Financial Institutions were. CCTV footage is invaluable, but often found to have been deleted far too soon by the time a request could be sent to the financial institution after law enforcement agencies had completed all their red tape. In such instances where CCTV footage was no longer available, the smallest detail, such as the behaviour of the suspicious customer, looking at their phone back and forth ‘x’ amount of times, or the colour and description of the rubber band(s), the description of the individual and their clothing and any accessories such as the backpack they carry. Many investigations come from the back capture of SMRs, where key patterns can be found based on the detail provided in the Grounds For Investigation and Investigation Notes. If there is anything we could do better, it is awareness and training, particular for our front line staff that have the ability to capture this information.

Human Slavery—The Fastest Growing Criminal Enterprise

Once again we were welcomed by Julian Hunn and his team at Flight Centre where Julian delivered an eye opening presentation about modern day slavery. It was frightening to learn that human trafficking is the 4th largest criminal industry in the world with annual proceeds estimated to be USD 150 billion.

Three key elements of human trafficking identified were:

  1. Action – recruitment, transport or harbouring
  2. Means – use/threat of force, coercion, fraud, deception etc.
  3. Purpose – to exploit another person.

While it was noted that there are regional variations to the statistics, on average the victim representation across the globe showed that 49% were women, 21% girls, 18% men and 12% boys. Things are skewed in the South East Asian region where the figures indicate that 80% of victims are men with an average age of 30 years, who are forced into labour such as fishing.

This highlighted the need to ensure your supply chain is appropriately vetted to ensure the sources of the commodities in your business is clean. From a corporate and financial institution perspective, the risk of reputational damage should be front of mind.

From a legislative perspective, the Australian federal legislation is expected to be in force by the end of this year. It is expected to follow the lead of UK legislation for the most part including a risk assessment, organisational policy, statement of action and an annual report of compliance for companies with a turnover greater than $100 million. The UK requires Board approval and acceptance of the statement which is not expected in the Australian legislation.

Julian believes the function of conducting the risk assessment may sit in the AML Operations Department based on the internal experience of this form of risk assessment, so financial institutions should be prepared for this. Additionally there will be a need to raise awareness, throughout financial institutions, of modern slavery as well as the organisations’ policy for managing this risk. Julian identified an important report as recommended reading in preparation for this legislation, and he suggested the 2017 report “Hidden in Plain Sight.”

The Australasian Chapter of ACAMS would like to once again extend the gratitude to Julian Hunn and Flight Centre for kindly hosting this event. We look forward to seeing you all at our next Brisbane event.

Trying to Uphold the Privacy Act in an Ever-Watchful World of AML Rules and Regimes

Approximately 55 ACAMS members and invited guests were treated to a lively presentation from John Edwards, Privacy Commissioner at an ACAMS local event hosted by Ernst & Young in Auckland on 29 August 2018. The presentation theme – Trying to uphold the Privacy Act in an ever-watchful world of AML rules and regulations – touched on the tension and sometimes adverse consequences that may arise when data gathering obligations are not balanced with suitable mechanisms to protect that data from improper use.

The presentation served as a useful reminder that while privacy is never absolute, particularly in AML/CFT areas such as crime prevention and community safety, reporting entities do have an important role to play in upholding fundamental privacy rights while discharging their AML/CFT related obligations.  Although the AML/CFT Act 2009 effects a specific over-ride of privacy in certain statutory obligations, the Commissioner reminded entities that once those obligations are discharged, they must take care in handling personal data because "their Privacy Act obligations start again."

Mr Edwards also provided an overview and insights into the new Privacy Bill which is expected to repeal and replace the Privacy Act 1993.  It will contain mandatory data breach notification, and additional ways in which it is designed to enforce information privacy principles.

Overall a very valuable presentation of an area that does not always receive the attention it deserves.  The Chapter extends its thanks to both the Privacy Commissioner and EY for its hospitality. 

The regional political and security risk landscape and its impact on AML and CTF

Hosted by Bank of Queensland (BOQ), with insights provided by Carla Liedtke and Joanna Ng of ControlRisks.

Control Risks, a specialist global risk consultancy, will explore the nexus between political and security risk and the prevalence of money laundering and terrorist financing. We will look at some key trends in the region and around the world driving political and security risk and how they are impacting AML and CTF.

Terrorism Financing in Australia and the Use of Financial Intelligence

Peter Forwood from PwC hosted our July event in Sydney. We had a full house of AML professionals gathered to increase their knowledge and exchange on the topic of Terrorism Financing in Australia and the use of Financial Intelligence to prevent it.

Stephen Dametto, Barrister at Banco Chambers was the speaker for the day. Stephen had created and led the AFP’s Terrorism Financing Investigations Unit (TFIU), and as such developed expertise on terrorism financing in Australia. Stephen started by giving an overview of Terrorism Financing associated with the definition from the World Bank: “Financial support, in any form, of terrorism or of those who encourage, plan, or engage in terrorism”. CTF really emerged following the 9/11 attacks, and spread to the rest of the world with the pressure from the USA. The intent was highlighted as key to understand if a suspicious activity could be qualified as terrorism financing. Stephen explained that even if common thinking is that CTF is not very important because it doesn’t prevent terrorism, past attempts tell us that funding was actually a key element of terrorism activities, and past terrorist attacks could have been worse with more funds. TF and ML share some similarities, with however key differences: ML is a circular process where the money usually comes from criminal activities and needs to come back to the initiator, while TF is a linear process and the majority of the funds could have legitimate sources and are benefiting another party.

Identifying terrorism financing is extremely hard because it is usually smaller amounts than ML, especially in Australia. Some terrorist attacks such as the Boston Marathon bombing were performed with less than $500. This makes it necessary to use financial intelligence to identify any activity on customer accounts which could indicate any terrorism financing: patterns of life, financial capability, correlation, red flags, etc. Financial information actually leaves a lot of traces and therefore can help identify suspicious activities; it is the best source of information to be used during investigations. In this context, the sharing of data between institutions, agencies and governments is also extremely important to prevent terrorism financing. But the sharing of classified information remains a challenge.

The question of deciding whether to close accounts where suspected TF activity is identified was raised by the audience. It was mentioned that AUSTRAC or law enforcement agencies could request regulated institutions to keep this sort of accounts opened for monitoring purposes and prevent having this suspicious activity go underground.

A set of case studies based on Stephen’s experience were then shared with the audience and discussed. The key highlights were that TF is mainly about small amounts, which makes it difficult to identify. The source of the funds can be completely legitimate and extremely diverse. It can come from criminal activities, donations, international trade, welfare benefits, legitimate business activities, etc. International politics play a key role in identifying which activities are related is TF and which are not. Humanitarian activities can be performed by terrorist organisations and used to also fund their activities, which makes the role of prosecutors even harder. In TF cases people are increasingly being charged for supporting foreign incursion instead of pure TF due to the difficulty of qualifying the intent behind the funding.

Effective Financial Intelligence

The Sydney ACAMS session for June was hosted by Tim Frederick and Challenger and attracted a lot of professionals with diverse backgrounds. The topics for the day were the following:

  • Public-Private Partnerships (PPPs) and future ways of working
  • International policy environment – enablers and what needs to change
  • Information sharing as a cornerstone of combatting financial crime.

Craig Robertson (Head of Financial Crime Threat Mitigation, HSBC) started with a presentation on his vision of the current relationship between the financial industry and AML regulators.  He mentioned that only 1% of SMRs triggered investigations, highlighting the need to move away from “defensive reporting” and instead combine rule based systems with new methods such as behavioural analytics. The end goal should be to make reporting on suspicious activities more accurate and effective.  He briefly highlighted the foregoing three strategies to make the SMR more effective and engaging, namely:

I.   Public Private Partnership around the world

He did a comparison of the different PPPs existing around the world. The local Fintel Alliance was shown as one of the most advanced partnerships with a true collaborative approach to regulatory reporting. He highlighted the need for even more collaboration and forums to share knowledge, experience and financial crime typologies.

The comparative matrix highlighted Australia being on top of the game with regards to financial intelligence sharing. On the other hand, USA has the strongest framework to make this strategy happen.

II.  Information Sharing

This strategy is crucial for global banks with cross-border presence.  He highlighted that Canadian model is ahead on this game.

III. International Policy Environment

According to the speaker, the building blocks to shape the International Policy Environment are:

(a)    Dealing with regulators
(b)    Addressing operational risk

The presentation was followed by a panel discussion with Craig and Mark McGoldrick (Team Leader – Financial Investigators, ACIC), moderated by Aub Chapman (Co-Chair of ACAMS Australasian Chapter). The take-away from the panel discussion are as follows:

  • The evolution of the relationship between regulators and the industry was discussed, and the future of the Fintel Alliance in particular.
  • Speakers agreed that the next step for the Partnership should be to increase its reach and open new channels to allow smaller institutions to also contribute in their own way.
  • The emergence of new types of players such as cryptocurrency businesses and Fintechs was also mentioned.  The panellists noted lack of effective SMR awareness and AML/CTF resources capability for these emerging sectors.
  • The panellists highlighted reporting entities generally observe that  the SMRs appear to be lost in blackhole in terms of no feedback received on the SMRs submitted.  The audience and the panellists  believe that Austrac should provide more feedback and collaborate more.  Nevertheless, Mark highlighted the value he saw in SMRs and assured the audience that the regulators are making good use of these reports in their investigations. He called for more data to be attached to the reports along with improved data quality to better support the authorities in their investigation activities.
  • The challenges faced in the industry all boils down to skills and resources capability.  Compliance professionals represent a small cut in the whole gamut of compliance space.

ACIC and Serious Financial Crime

We were pleased to be hosted by Paul Gifford and his team a QSuper for our latest event in Brisbane and were treated to an outstanding presentation by Mr Carey Stent from the Australian Criminal Intelligence Commission (ACIC).  Carey is the Manager of the Emerging Threats Intelligence Hub at ACIC, based in Brisbane.  He was a former QPS Detective Senior Sergeant for 18 years and has investigated domestic and international organised crime for over 25 years. 

The presentation encompassed the work of the ACIC, with an overview of some of the work in the Serious Financial Crime environment and the targeting of transnational serious organised crime.

It was surprising to learn that the ACIC assess that 75% of the persons of threat to Australia are actually based off shore.  While we have significant crime syndicates operating within our border, the fact that the majority of serious criminal activity is due to international crime rings is an eye opening fact.  Mr Stent said that the typologies relating to importing tobacco or drugs and the money laundering associated with these crimes is the same.

Carey then took the audience on a ride through Task Force Eligo, which was a National Task Force established in 2012 and operated through to 2017. It was a special investigation into the use of alternative remittance and informal value transfer systems by serious and organised crime.  They were able to identify 480 targets who were previously unknown, arrested 475 people on 1095 charges.  The Task Force has seized more than $580 million worth of drugs and assets, including $26 million in cash.

He also discussed how the use of professional facilitators was a key risk in todays society.  He said that lawyers and accountants were capable of phoenixing companies, set up off shore companies, abusing Trust instruments and were adept at exploiting the legal loopholes in our systems and laws. 

The ACIC is now seeing to an escalation in the use of tech and cybercrime through the use of cryptocurrencies, EFT transfers, company structures and secure communications such as WhatsApp.

Another interesting point that he made was that the ACIC has the ability to establish an MOU with non-law enforcement agencies in order to share with information with the private sector.  This would be a valuable process which would be important to manage effectively.

We’d like to thank Carey for his time and professional presentation.  The audience was fascinated by the size and extent of criminal operations impacting on Australia and peppered him with dozens of questions which added even more value to the members.

Phase 2 AML/CTF Act in New Zealand

On a stormy Thursday evening, the Melbourne members of the Australasian Chapter were hosted by BAE Systems Applied Intelligence to hear from Dr. Nicholas Gilmour.

Dr Gilmour, who was a former New Zealand FIU Adviser and a key contributor to the development of the Phase 2 AML/CTF Act in New Zealand, shared with us the journey New Zealand has been on and what we can expect to see as the Act comes into effect. 

Through his honest, insightful and humorous stories from the ‘coalface’, we were challenged to turn our attention to what we could learn from the New Zealand experience and apply in an Australian context. 

The panel discussion, led by Paddy Oliver, Managing Director AML Experts, fielded a number of questions from the floor, tackling a number of themes, from certification, conflicts of interest to what’s next.

The law of unintended consequences; Criminals looking to exploit the weakest link will use any avenue to legitimise their ill-gotten gains – be ready to see new typologies evolve as criminals shift their attention as gaps are closed.

Dr Gilmour identified the five phases of implementation: Panic, Hesitation, Reluctance, Confusion and Pride.  I look forward to experiencing the final phase when Australia is ready to launch Tranche 2.

Questions, discussions and hypotheticals ensued over drinks.  We thank Mark Thomas and BAE Systems Applied Intelligence for hosting the event and Dr Nicholas Gilmour for his insight and honesty.    

An Evening with a Whistleblower – Do you need to think AML

Emerging International Standards in Enhanced Due Diligence

Although anti-corruption and anti-money laundering laws can differ widely across jurisdictions, there is a strong consensus emerging on what constitutes effective enhanced due diligence.

Cross-border investigations and close collaboration between national enforcement bodies is driving consistency in what a regulator expects to see, whether in Melbourne or Mumbai.

The recent Crimes Legislation Amendment Bill will introduce a new offence of failing to prevent foreign bribery, further increasing the requirement for Australian firms to focus not just on the risks within their business, but also on the risks within their third parties.

In this interactive discussion, we will address ‘what good looks like’ and consider the conclusions of the Senate Committee’s report on foreign bribery.

  • What third parties or customers am I screening and why?
  • How do I know when I have conducted sufficient due diligence?
  • How to address red flags as they emerge
  • Example of ‘failure to prevent’

Welcome to the first event in Queensland for 2018!

The first Queensland ACAMS event for 2018, hosted by Julian Hunn and his team at Flight Centre was a sellout event. Once again it was great to see diversity in the room including people from the remittance sector, payment systems, superannuation and banks. In fact, an encouraging factor was that the banking sector was outnumbered by the others which is vitally important to have the broad range of sectors represented to share the learnings of others.

Julian Hunn gave the audience an overview of the different ways that the various Flight Centre businesses were captured under both the AML/CTF Act and the legacy obligations of the Financial Transaction Reports Act.  He also gave some insights to the challenges faced by the organisation, some of which were shared by others and it stimulated some great questions and conversation.  Central to this conversation was the need for a thorough risk assessment to be able to install any appropriate solutions.

We also had a small panel session with Michelle Milts (Suncorp), Paul Gifford (QSuper) and Julian Hunn (Flight Centre).  They discussed the various critical AML/CTF issues shaping Australia this year.  Issues such as the Royal Commission, technological solutions and digitization were raised.  A concern around tech solutions is the speed of redundancy of the IT.  It was acknowledged that an IT solution may only be valid for 3 years before the changes in business required a different solution.  In fact an example was given where a multi-national bank undertook an IT project and by the time it was ready to be rolled out it was already redundant. They also addressed how the enforcement action against Tabcorp and CBA affected their day to day work. It was interesting to learn that it made things difficult for some and yet easy for others, who were able to leverage off the pain of others. It helped them to communicate the seriousness of non-compliance to the senior executive.  Finally, the discussion turned to “what keeps them up at night”? There was great interest in the ‘unknown unknowns’ to come out of the Royal Commission, mitigating reputational damage and management of sanctions were also highlighted as a key concerns.

How AML/CTF reporting influences the regulators behavior

The final event for 2017 in Queensland was kindly hosted by Brad Bardell and his team at CUA where we saw a great turn out to listen to Mr Chris Mohr, Director Intelligence from AUSTRAC. Chris provided some interesting strategic statistical graphs which was valuable in informing the audience how AUSTRAC looks at the reports provided by various industry sectors.  Previous seminars have shown how law enforcement agencies use financial intelligence at a tactical and operational level and it was interesting to see a different view of the strategic analysis that is undertaken to inform decision makers in AUSTRAC and indeed other agencies who use the information.

Chris also discussed how the information was used to inform the way AUSTRAC engages with different industry sectors. While the overwhelming majority of reports come from 25 reporting entities, it’s important that AUSTRAC engages in a more helpful manner with other reporting entities to encourage reporting rather than going straight for enforcement action. One of those ways was attending this seminar to provide information back to industry.

It was also interesting to learn the continuing evolution of the Fintel Alliance which has been operating for about 12 months now. He indicated that within the next 3 – 6 months many more reporting entities would be invited to take part in this initiative.  The critical component of this Alliance is the ability to obtain information “at the speed of light” rather than waiting for days.

We are all looking forward to the Christmas break and then kicking things off again in 2018. Please have an enjoyable and relaxing break with your respective families and friends.

Herbert Smith Freehills: Changing attitudes of the legislature and enforcement agencies in relation to financial crime

We are pleased to have Paul Wenk, Partner Herbert Smith Freehills and Kate Weinstock Senior Associate Herbert Smith Freehills share with us their observations about:

  • The changing attitudes of the legislature and enforcement agencies in relation to financial crime
  • The key focus for various regulators
  • What’s on the horizon both in Australia and overseas, and
  • Implications for business

Blockchain to help KYC?

Michelle Milts and Jo Canavan from Suncorp kindly hosted the latest event in Queensland, where the key note speaker, Nick Giurietto, CEO Australian Digital Commerce Association, discussed all things blockchain and cryptocurrency.

Clearly this is a significant change in the use of technology to manage information into the future. Putting Bitcoin and it’s blockchain to one side for a moment, Nick took the audience through a range of issues surrounding blockchain technology which stimulated significant discussion and questions. Sometimes referred to as Distributed Ledger Technology (DLT), blockchains are driving forward to be the ‘Shared Source of Truth’. With examples such as Everledger and Hyperledger the world is moving forward in its uptake of DLT and the game-changing power it brings. In Australia, the ASX is moving forward with advanced plans to use blockchain to replace the CHESS clearing system, in what was described as too big to fail.

We are already seeing many examples of smart contracts being linked to real time monitoring of events and Nick says that while Australia is “probably around a B+” in our uptake of blockchain technology, we should be doing more, and great business opportunities exist. He indicated that regulators in Canberra were moving forward, and agencies including AUSTRAC have a key role to play, but we are behind other countries such as Canada, China and interestingly Estonia.

DLT has a role to play in terms of KYC in the near future, if things are done correctly. Trust is a critical component and building that trust will take time. One of the key issues that regulators and industry are grappling with is the ‘certification’ as to the accuracy or authentication of the initial identity documents. Once an identity is authenticated and certified it can then enter the blockchain as a person’s shared source of truth about their identity. That ‘identity token’ can then be relied upon by others as a fully verified identity, thus greatly speeding up the KYC and on-boarding processes currently being used by financial institutions around Australia and the world.

The AML professionals in the room were extremely interested in learning more about the mysteries of blockchain and how it is expected to impact on their professional and personal lives. It’s more than watch this space, it’s more like get cracking because the future is here.

Innovation in KYC

Regulatory pressure, customer service and increasing costs are the three factors driving Know Your Customer innovation, so how can jurisdictional managed services help? Thomson Reuters are delighted to collaborate with ACAMS and AUSTRAC to invite you to an evening of insights and discussion.

ACAMS / New Zealand Police FIU 2017 Conference

ACAMS Australasian Chapter continued with its successful partnership with the New Zealand Police in staging the Anti-Money Laundering and Countering Financing of Terrorism Conference 2017 at Wellington on 13 and 14 September. Reporting entities were also extended the opportunity to attend Supervisory workshops on the day prior to the conference where the three AML sector supervisors took the opportunity to present on key topics relating to their respective sectors.

The conference was staged at Te Papa Museum and attended by just over 300 delegates including a range of new phase 2 reporting entities which, recently enacted legislation will bring on stream over the next two years.

The Conference was opened by the Commissioner of Police who reminded those present that it was the collective efforts of both the private and public sectors that were necessary not just to disrupt but ultimately to dismantle the networks that supported financial crime.

There were a range of fascinating presentations that followed, exploring various versions of the financial crime partnership network in action ranging from:

  1. the investigative value generated by suspicious transaction reporting;
  2. the power of the fourth estate and investigative journalism in exposing the Panama Papers and in influencing change internationally – in particular NZ’s response involving a Government enquiry into Foreign Trust Disclosure Rules which embraced a range of related areas including AML; and
  3. the co-operation between NZ Police and their Chinese counterparts which resulted in NZ’s most significant settlement to date involving the alleged proceeds of crime.

There were also significant presentations on the complexities of trade based money laundering; practical insights on money laundering and terrorist funding from a Special Agent at the FBI; and a practitioner’s view and step by step analysis of a reporting entity’s transaction monitoring system.

ACAMS Australasian Chapter Board members Gary Hughes and Aub Chapman combined in a joint presentation providing trends and tips from around the APAC region exploring the thorny issue of ultimate beneficial ownership. They finished by discussing recent enforcement related action in the region and in particular the significant actions taken by AUSTRAC arising from AML related breaches by TABCORP and the ensuing $45m settlement and the current action and statement of claim involving the Commonwealth Bank of Australia.

Overall some insightful presentations from a range of quality speakers over the three days to provide delegates, including the many ACAMS members who attended, much to dwell on.

Innovation in KYC

On Thursday night, seventy Financial Crime professionals came together in Melbourne to hear from AUSTRAC and industry experts on advancements in customer due diligence – the foundation of all AML/CTF and Sanctions Compliance Programs.

Our first speaker, Paul Zahra, Head of Customer On-boarding and Working Capital Services, ANZ Banking Group, manages a market leading global customer on-boarding proposition for MNC to Small Business customers across 30 countries in Asia and the Pacific. Paul took an innovative approach to his presentation, abandoning the traditional slide deck for a whiteboard and an easy to follow diagram to take the audience through how he established a KYC Utility at ANZ. In taking questions from the floor, Paul stressed the keys to success for a KYC onboarding utility are accountability and collaboration. The Utility must be accountable to get the processes right, but, at the end of the day, Relationship Management own the customer and the risk, and therefore must know their customer – this cannot be delegated.

The theme of collaboration, and its importance in protecting our community against financial crime, continued as Richard Bunting, Director of Strategic Intelligence and Policy, AUSTRAC, and Mark Crawley, Compliance Manager, AUSTRAC, provided a glimpse into the future. In their presentation “Strengthening, Streamlining and Simplifying through consultation and partnerships” they shared learnings from the recent KYC Summit in Canberra. The audience, eager to learn how legislation is keeping pace with the digital world, heard how the Regulator is working to be more flexible in its response, enhancing technology and continuing to work with industry to further strengthen the Act. This included how Blockchain has the potential to be used for Smarter Contracts and how digital currencies may use device information for verification purposes.

Our host for the evening, Richard Storey, Head of KYC & On-boarding Pacific for Thomson Reuters, then led the room on a discussion on how data, operations and technology, can deliver a customer-centric, cost-effective KYC fingerprint. Once again the theme of collaboration was key. Richard shared how the four major banks in South Africa over the last 12 months, have tackled the challenges of customer due diligence from a jurisdictional perspective by leveraging Org ID KYC Managed Service to identify and classify a client’s risk category, verify their identity, and screen and monitor all related parties to create a KYC record.

The evening concluded with an opportunity to meet up with old and new financial crime colleagues.

How 1 SMR launched a 3 year organised crime investigation

The first ACAMS event in Queensland for many years was extremely well received by the 40 attendees on 30 August. We would like to thank Simon Phinn from Bank of Queensland who kindly hosted and catered for the event which brought together AML professionals from the banking, foreign exchange and investment fund sectors as well as a number of professional service providers.

The audience was treated to a great case study of criminal activity presented by Detective Karen Martin and Detective Graeme Edwards from the QLD Police. The case study examined the investigation into a serious boiler room scam (referred to by police as Cold Call Investment Fraud) which was launched by the submission of a Suspicious Matter Report (SMR) in 2013. The SMR triggered a 3 year investigation which saw the arrest of 15 people and is heading to the courts next month. As a result of this investigation it also uncovered a number of other ongoing organised crime syndicates which are now under investigation. The Detectives were very clear in their desire for the continued provision of high quality SMR reports as “they often provide the missing piece of a puzzle” Det Martin said.

The interest generated by the case study saw the audience ask questions, for nearly an hour, relevant to their work such as the need for good KYC information as well as the implications for determining Ultimate Beneficial Owners within company structures. This was particularly critical due to the prevalence of phoenixing companies using ‘dummy directors’ who were mostly unemployed, unskilled people acting at the direction of their criminal masters. Discussions also evolved into the role of other regulators such as ASIC to undertake due diligence prior to registering companies which could greatly assist reporting entities with their KYC/UBO obligations.

We look forward to the next event on 4 October, kindly hosted by Michelle Milts at Suncorp, where the key note speaker, Nick Giurietto, CEO Australian Digital Commerce Association, will be discussing cryptocurrencies and blockchain technology.

ACAMS / New Zealand Police FIU 2017 Conference

The annual ACAMS/FIU financial crime conference is firmly established as New Zealand’s largest event of its type. Now into its 5th iteration as a joint venture with the NZ Police FIU, the Board of ACAMS Australasia is very pleased to bring you advance notice of this major event in Wellington in September 2017.

Theme: Money Laundering and Terrorist Financing: a Global Problem

Venue: National Museum of New Zealand, Te Papa Tongarewa, Wellington

ACAMS FINANCIAL MEMBERS RECEIVE 10% DISCOUNT OFF REGISTRATION COST, and Price Freeze at 2016 conference fee, no cost increase

12 September – Supervisor workshop option (Booking required prior to conference)
13 September – Conference Day One: 9.00am to 5.00pm; 7.00pm – 9.00pm Networking and Drinks function
14 September– Conference Day Two: 9:00am to 4:30pm

Presentations will include international keynotes and local experts to focus on the developments on both nationally and internationally including:

  • Gatekeepers and International Controllers
  • Trade Based Money Laundering
  • Use of Money Mules
  • Prescribed Transaction Reporting
  • Reliance on Third Parties
  • Foreign Trusts and new disclosure rules (post-Panama Papers)
  • The $43m “Citizen Yan” case recently concluded in the High Court.

Further information and draft Agenda will be available in the near future.

Registrations will open in the first week of July.

NZ Financial Markets Authority – AML Monitoring and Sector Risk updates

ACAMS ran another very popular local event in Auckland, on the topic of the Financial Markets Authority’s role in AML/CFT and latest Monitoring and Sector Risk Assessment updates for the sectors it supervises.

Senior Advisors Lena De Fonseca and Brandt Botha took time out from a busy monitoring and supervisory workload to address our members.

We were able to hear from the FMA at a good time in the organisational life cycle, as both the New Zealand AML/CFT regime and its own approach as a Supervisor continues to mature. Attendees were able to get an advance sneak preview at the new Sector Risk Assessment from the FMA, the first for its sectors since 2011 (by the then previous regulator, the Securities Commission). We were pleased to get ahead of the curve before the SRA was publicly released to the market the following month.

A copy of the SRA can be found here:

We were kindly hosted on this occasion by ANZ Bank and, with attendees limited on the night to 50 persons, it was a case of “get in quickly” for those keen to be at our latest successful training and networking event.

Not just the Financial Sector in the gun – Phase 2 extensions in NZ and Australia

As a result of Panama Papers politics, New Zealand looks set to move ahead swiftly to extend the AML-CFT regime to professional gatekeepers, DNFPBs and high value asset dealers. The Ministry of Justice has been weighing up submissions received, and a draft Bill is expected in early 2017. Our expert panel discussed what it will mean in New Zealand, both for the new sectors covered and for existing reporting entities.

Gareth Pindred of KPMG Advisory-Forensics spoke on issues for the Accounting profession; Gary Hughes barrister provided a perspective from the Legal profession, and visiting expert Neil Jeans helpfully commented on what NZ’s speed of legislation and approach might mean for Australia’s own tranche 2 expansion plans.

The event doubled as the ACAMS Christmas drinks in Auckland (kindly hosted by KPMG) and approximately 65 attendees enjoyed the opportunity to catch up informally after the seminar.

NZ Anti-Money Laundering and Countering Financing of Terrorism Conference 2016

Now into its third year as an ACAMS Australasia JV with the NZ Police, this Conference was a big success, with many favourable comments from the 250 attendees that it was the best event of its type for several years. One attendee reportedly said it was “life changing for her” – although admittedly she was a first time ACAMS conference rookie!

The theme of “Private – Public Sector Partnership” lent itself to many interpretations and discussions as to how reporting entities can become more cohesive and more helpfully involved with public sector crime fighting objectives.

Several international and New Zealand keynote presenters and topics were very favourably received, including Steve Farrer/Darren Coulston with a presentation on (People Trafficking and Slavery) that was as shocking as it was thought provoking. Professor Michael Littlewood made sense and simplicity of a complex topic in NZ’s Shewan Report proposals after the Panama Papers/Tax Haven revelations. A fascinating insight into how the banking sector can contribute strongly and positively to analysing and anticipating terrorist recruits and potential terrorist fighter movements was another top-quality crowd favourite session.

As always, the drinks/networking function at the end of Day 1 was a big hit. It has to be said that Trans-Tasman discussions and networking continuing well into the evening.

We have set a very high bar for this major Australasian conference, which would not be possible without the huge effort of a small number of volunteers. Planning is now underway for the 4th official JV event again in September 2017.

2nd Annual Financial Crime Summit

The second Annual Financial Crime Summit was held on 16-17 Aug 2016. The event was organised by IQPC and was supported by ACAMS Australasian Chapter. ACAMS consumables and magazines were distributed to the attendees at the 2-day conference. Crispin Yuen from the Chapter’s Board chaired the event and was supported by Chapter Working Group members, Ash Walters and Carlos Sanchez.

Day 1 started with a guest speaker from the US Department of Justice FCPA Unit, who spoke via teleconference to a room of over 70 attendees. The program continued with a panel discussion on building a global anti-corruption program. Panel speakers from the US IRS, Bank of Tokyo- Mitsubishi, NSW Police Force (Fraud and Cybercrime Squad) and Association of Certified Fraud Examiners spoke passionately about their views on culture, expectations and the definition of a bribe. It was a lively discussion and involved questions from the audience. A member on the panel did not fully agree with the comments from the earlier session on voluntary self-disclosure. The day continued with presentations, roundtable and discussions with speakers from Pitney Bowes, Australian Federal Police (Crime Operations), AUSTRAC, DFAT, ANZ, ATO, UniSuper and SWIFT. The day ended with social networking drinks hosted by ACAMS with canapés served.

Day 2 continued with speakers from International Bar Association, DFAT, ANZ, Weir Group, Attorney-General’s Department and AIG. Highlights include the panel discussion on complying with foreign bribery, corruption and sanctions. Panel speakers covered on the international linkages of our economy and how we need to hardened the environment to deter organised crime. It was interesting to note a comment on how the FATF Recommendations is used as a reference for organised criminals to avoid being detected. The presentation made by the AGD highlighted the challenge faced internally within the Australian Government where a Commonwealth fraud control framework is needed to be implemented across 180 different Commonwealth entities with different fraud risks, priorities and arrangements. The day closed with the Ask the Experts Session, covering Tax Evasion, AML Compliance Challenges, Sanctions Compliance, Risk Appetite within an organisation.

The summit was well received by the attendees based on positive comments on the quality of the content and speakers, as heard during the networking session and break times.

Anti-Bribery and Corruption in New Zealand

Hosted at KPMG, a panel discussion on Anti-Bribery and Corruption was held with 4 speakers from the Serious Fraud Office, New Zealand Police FIU, Inland Revenue Department, and ACAMS.

The focus was on detection or prevention measures that explore the overlap of ABC prevention and AML programmes, including commentary on the NZ Bribery legal framework and International Conventions, case studies, and risk factors or indicators that financial institutions can look out for.

Almost 70 attendees thoroughly enjoyed the event, and several comments were made that it was an important and often under-explored topic for New Zealand.

The Panama Papers

Control Risks presented on the implications of the Panama Papers for financial services organisations, now and into the future. The presentation focused on the leak itself, the tactical response, the potential impact on financial services organisations and others as these leaks become increasingly prevalent, and the potential response from regulators. Speakers included Mark Pulvirenti, Carla Liedtke and Allanna Skeels.

FATF and Tabcorp

29 attendees made it to the ANZ conference rooms to hear a discussion on both the FATF plenary meeting relating to terrorist financing held in Paris earlier this year and to have an interesting discussion on the document requests made as part of the AUSTRAC v. Tabcorp litigation.

Milan Girgovic of the ANZ’s financial crime intelligence team gave an interesting and considered download of the FATF plenary and what ANZ are trying to do in relation to Terrorist Financing and Foreign fighters. The development of relationships with the security agencies and the importance of timely information were stressed as well as some typical red flags seen across banking. One salient but slightly off point comment from the floor was that the foreign fighter’s legislation is not linked to the AML/CTF Act at this point in time and, whilst there is no technical requirement to include this as a risk in your ML/TF risk assessment, it would be wise to start thinking about it.

Paddy Oliver talked over some of the interesting considerations coming from the document requests made as part of the AUSTRAC v. Tabcorp litigation. Several of these were – recognising that suspicious matter reporting includes the requirement to report an matter that may raise a suspicion that any state or federal law has been broken – as Paddy kindly advised us not even he knows all the laws. Another interesting discussion rose over the apparent suggestion by AUSTRAC through the charges that if one part of an AML/CTF program was deficient then there was no program in place. It is highly recommended that everyone keeps an eye on how this progresses and despite some requests for the matter to proceed to judgement and therefore provide some certainty it may be some time before the whole matter is resolved.

Drinks after the event aided the flow of the discussion and everyone appeared to enjoy themselves.


Held at ANZ on 29 March 2016, Nick Giurietto, CEO and Managing Director of the Australian Digital Currency Commerce Association (, the peak industry body representing Bitcoin and Blockchain businesses in Australia was our keynote speaker.

Following a Senate recommendation from 2015, ADCCA is leading the development of a Digital Currency Industry Code of Conduct designed to clearly distinguish reputable operators from those with inadequate compliance controls. Nick provided an update on the development of the Code of Conduct which includes but goes beyond AML/CTF requirements. He also provided insight into the perspective of key regulators.

Cybercrime risks – the costs and consequences of organised crime involvement

ACAMS was pleased to present a panel discussion on this hottest of topics for 2016, with experts from Insurance risk, Forensic, IT, and Policy perspectives all helping to identify and deal with the growing involvement of organised and financial crime groups in cybercriminal activities. Hardly a day goes by without some new cyber risk presenting itself. An increasingly sinister trend is, for example, phishing or hacking and data theft/exposure followed by financial extortion by an organised crime gang. Some in the media have even dubbed 2016 “the year of online extortion”.

Held at PwC, speakers and panelists included:

  • Campbell McKenzie – Director, Forensic Technology Solutions at PwC in Auckland
  • Patrick Hung – Head of Information Security, Westpac Bank
  • Heather Ward – Principal Advisor, National Cyber Security Policy Office – ConnectSmart (Department of Prime Minister & Cabinet)
  • Ian Pollard – Managing Director, Delta Insurance
  • Chair/Moderator: Gary Hughes of ACAMS and Wilson Harle

Cash Intensive Business – Vulnerabilities from a Money Laundering Perspective

Held at KPMG, our guest speaker, Dr Nicholas Gilmour spoke about the vulnerabilities of cash intensive businesses. Despite large scale focus on combating Money Laundering, cash intensive business remains a viable and popular method to launder criminal profits. This presentation will outline the exploratory findings of research recently conducted in the United Kingdom that sought to identify the process, steps and vulnerabilities behind Money Laundering through cash-intensive business, while highlighting key facilitators that enable this method of money laundering using a documented case study.

Is New Zealand a tax haven?

Panel Discussion

Australasian Chapter Event in Melbourne

Nick Griffith

Nick Griffith
Regional Director of Business Development – Australia & New Zealand, ACAMS

Mr. Griffith is the Regional Director of Business Development, Australasia at ACAMS. With more than 20 years of experience in the financial-crime related industry, Nick has been actively engaged with the professionals from the public and private sectors, especially with his support of the ACAMS community as a result.

Mr. Griffith previously held the position of Regional Sales Director, North Asia with Thomson Financial where his work centred on providing compliance solutions for the major financial institutions across the region.

Mr. Griffith was the Asia Pacific founder of World-Check, a globally recognised and market leading AML/CTF and Sanctions compliance solution which today is part of Refinitiv and used by the 50 largest banks in the world as well as several thousand other regulated entities.

As an independent consultant he worked to successfully help build both Fintech and Regtech businesses.

Mr Griffith is highly client-centric and is passionate about providing the right solution to meet the Member’s specific needs.

He attained a Post-Graduate Diploma in International Marketing from Kingston University, London


Aub Chapman

Aub Chapman, CAMS-Audit

Prior to his retirement, Aub Chapman was a career banker with over 42 years of professional experience.

In his last role at Westpac Banking Corporation, he was responsible for managing a number of functions including Group Fraud Control, Physical Security, Business Continuity Services, Cash and ATM Services as well as managing the group’s compliance with AML/CTF legislation.

Since his retirement, Aub has been consulting in both the public and private sectors, not only in Australia, but also internationally. He specialises in controls against financial crime and management of cash services. His international experience includes assignments for the United Nations, the Asian Development Bank, The Eurasian Group on Money Laundering (on behalf of the FSVC), Bank Negara Malaysia, Institut Bank-Bank Malaysia and the Labuan Offshore Financial Services Authority. He has been a guest speaker at a number of international AML/CTF conferences and international conferences associated with the cash services industry.

Aub is a founding member of the Australasian Chapter, a member of the ACAMS Education Task Force and received the ACAMS AML Professional of the Year award in 2009.


Martin Dilly

Martin Dilly, CAMS-Audit

Martin is a Director of MD/AML, a specialist AML firm providing consulting and auditing services in New Zealand, Australia and the Pacific Islands. He has consulted full-time as an AML specialist since June 2012. In that time, he has assisted a wide range of entities including registered banks (local and foreign), casinos, large insurance companies, money remitters, foreign exchange traders, fund managers, and trustee companies.

Prior to becoming an AML consultant, Martin commenced his career as a corporate lawyer at Russell McVeagh, one of New Zealand’s largest law firms. He went on to hold held senior legal and compliance roles at ABN AMRO Bank N.V. – New Zealand branch as Associate Director, Legal and Compliance, and with Heartland Building Society, then New Zealand’s largest non-bank deposit taker, as Head of Compliance and Company Secretary.

Martin received his certification as an Anti-Money Laundering Specialist (CAMS) in May 2012, and was the first in Australasia to gain the CAMS Audit advanced certification in April 2014. Martin is also a member of the ACAMS teaching faculties for CAMS and CAMS-Audit.

He also holds degrees in Law and Commerce (Economics) from the University of Auckland. 


Crispin Yuen, CAMS-Audit, CISSP, CISA
Communications Director

Crispin Yuen is a Financial Crime Risk and Compliance specialist with extensive experience in regulatory compliance, risk controls, governance and assurance. Crispin runs AML Sanctions, an online platform that focuses on Financial Crime developments in the financial services industry.

In his last role, as Head of Compliance, Australia and New Zealand at Ria Financial Services, Crispin was tasked to remediate, redesign and rebuild the company’s regional AML/CTF and Sanctions Compliance program.

Crispin previously worked at AMP, Deutsche Bank, CBA, Deloitte, Ernst & Young and OCBC Bank. At AMP, Crispin assisted in the harmonisation of AMP and AXA’s AML/CTF frameworks for use by its post-merger entity. At Deutsche Bank, Crispin was the Compliance Manager in its Central Compliance team responsible for the bank’s Asia Pacific businesses. His role covered the detection and prevention of potential market abuse, insider trading, securities fraud and market manipulation. In 2008, while at Deloitte, Crispin was seconded to ANZ Bank to be part of the bank’s AML & Sanctions team in resolving its OFAC sanctions matter.

Crispin’s in-depth experience in remediating and resolving deficiencies raised in both OFAC and AUSTRAC enforcements distinguishes him as one of less than a handful of professionals with such experience in Australia.

Crispin is a Certified Anti-Money Laundering Specialist (CAMS), a Certified Information Systems Security Professional and a Certified Information Systems Auditor. Crispin co-authored the 5th edition of CAMS study guide and exam questions. He is the author of the book on the revision to the FATF 40 Recommendations, available on At the invitation of the Australian Parliamentary Joint Committee on Law Enforcement, Crispin spoke as an industry witness at the “Inquiry into Financial Related Crime”.

Crispin is an approved External Auditor for the purpose of the AML/CTF Act. Crispin has been serving the ACAMS Australasian Chapter since 2007.


Caitlin Cook

Caitlin Cook
Co-Programming Director (Melbourne)

Caitlin Cook is a Change Lead in in ANZ’s Enterprise Financial Crime Team located in Melbourne. The role is responsible delivering projects and strategic change across the Financial Crime Portfolio in ANZ.

A Financial Crime Professional, Caitlin has worked in Capability, Process Development and Change Delivery to build and enhance Financial Crime operations in Melbourne, Chengdu, Bangalore and Manila.

Caitlin has spent more than 10 years inthe capability and change, across a number of different business units in a wide range of roles including risk, operations and project management, training and communications. Caitlin has worked in Australia and Ireland for banks including ANZ and Rabobank.

Caitlin is currently completing a Masters in Human Resources and is passionate about developing Financial Crime Capability to meet the growing challenge of combating financial crime.

Todd Harland

Todd Harland
Co-Programming Director (Brisbane)

Todd Harland is the CEO of AML Solutions International, a specialist consultancy firm focused on the development and implementation of AML/CTF programs and procedures at an enterprise level and with the development of FIUs at a government level.

Prior to forming his company he had a distinguished career spanning across multiple areas of compliance, training, law enforcement, intelligence, counter terrorism, and foreign government assistance, including 15 with the Queensland Police and 4 years with AUSTRAC.

As an AUSTRAC Authorised Auditor Todd has conducted AML reviews for Australian businesses both large and small. He has conducted AML/CTF workshops across the African continent and throughout the Middle East and Gulf States. He has also been asked to present at multi-national seminars regarding the financing of organised crime.

Todd holds a Post Graduate Certificate in Management, Bachelor of Business and various risk and audit qualifications.


Irina Samoylova

Irina Samoylova
Co-Programming Director (Sydney)

Irina Samoylova Kunces is a Risk, Control and Compliance Specialist with over 14 years of cross-continental experience in Corporate and Institutional Banking, Retail and Mortgage industry, specializing in financial services product and client segments, global financial crime compliance, training development and business advisory.

Irina is a Founder and Managing Director of a NewEra Business Consulting company, helping financial services industry to build effective AML Program framework. In this capacity, Irina recently joined Simple KYC as Head of Strategy and Corporate Partnerships to help driving regulatory agenda and promote sustainable innovation.

Prior to that, Irina was a Regional Head of Financial Markets, Corporate Finance and Client Segment within Financial Crime Advisory with Standard Chartered Bank, Americas, providing thought leadership and advice regarding the identification and mitigation of financial crime risks and controls affecting the business in the Americas across banking products and client segments. 

Prior to joining Standard Chartered, Irina was the AML Advisory Compliance Manager with JPMorgan & Chase managing the AML compliance program for the CIB businesses globally. In that role, she advised Treasury Services businesses on BSA/AML compliance issues and requirements for high risk product sets, including Core Cash, Cash Vault Services, Escrow Prepaid Card and Trade, and specialized client segments. Prior to joining JPMorgan & Chase, Irina was with Goldman Sachs & Co in various Risk & Control roles across Americas and internationally.

Prior to moving to Australia, Irina served on the Executive Board of ACAMS New York Chapter for nearly 4 years, helping driving ACAMS training agenda and industry Financial Crime Compliance awareness. Irina holds International Diploma in Anti-Money Laundering from Manchester Business School joined program with International Compliance Association. Irina also holds a Specialist Certificate in Anti-Money Laundering Risk in Correspondent Banking.


Gary Hughes

Chris Faherty, CAMS
Co-Programming Director (New Zealand)

Chris is a Director at Ernst & Young (EY) and leads the firm’s Forensic & Integrity Services practice in New Zealand. He has nearly 15 years of experience providing consulting services in the Financial Services sector – specialising in Financial Crime compliance, regulatory response and investigations – to clients based in the U.S., Europe, Asia and Australasia.

Chris has worked with global financial institutions and asset managers to address regulatory requests and enforcement, improve and assess anti-money laundering, economic sanctions and anti-bribery and corruption compliance programmes; and lead financial crime investigations.

He has a strong knowledge of KYC/CDD/ECDD frameworks and customer risk-ranking protocols, as well as expertise in the use of investigative technologies. He has led several engagements that were under regulatory order aimed at assessing financial crime frameworks for gaps, remediating compliance programmes and conducting technology-assisted look-back investigations into suspicious transactions and customers. He has also led several financial crime benchmarking projects for global banks, assisting them in understanding industry practice surrounding KYC frameworks and correspondent banking.

Prior to joining EY, Chris held executive positions at several boutique consulting firms. He started his career as a journalist, most recently covering Criminal Justice for The New York Sun. He has a Bachelor of Arts from the University of Vermont and a Master of Business Administration in Accounting from Baruch College, Zicklin School of Business.  He is a Certified Fraud Examiner (CFE) and a Certified Anti-Money Laundering Specialist (CAMS).


Rodney Willis

Rodney Willis, CAMS
Co-Membership Director (Australia)

Rodney is currently working at Westpac as an AML/CTF manager for the Group AML/CTF team which sets and monitors compliance across the Westpac Group’s policy, program and standards.

He also provides technical guidance and support to AML/CTF representatives across the Group.

Prior to working at Westpac, Rodney spent ten years working in various roles across the financial services industry (banking, superannuation and asset management). He held a variety of responsibilities ranging from quality assurance and client services to relationship management. During that time, he gained operational AML/CTF experience by being exposed to the complex frontline impacts that are a reality among global asset management organisations doing business in Australia.

Rodney is a Certified Anti-Money Laundering Specialist (CAMS) and holds a Bachelor of Science.


Toby Noble

Toby has over 25 years experience in investigating and managing financial crime in a range of Australian banks, from the large to the very small. He is tertiary qualified holding a Master of Finance and Graduate Certificate in Fraud Investigation, and currently specialises in AML/CTF. Career highlights include having participated in industry level negotiations with government prior to Australia’s current AML/CTF regime being introduced, and designing, implementing and managing AML/CTF frameworks and operations at a number of Australian banks.

His current focus is to build organisational capability in AML/CTF at his current role with Teachers Mutual Bank Ltd and to contribute more at an industry level, having launched a mutual banking sector Best Practice Group in 2017.


Chapter Advisory Board

Gary Hughes

Gary Hughes
Chapter Advisory Board Member

Gary Hughes is an independent barrister in Auckland, specialising in regulatory investigations, advice, prosecutions and court disputes. Involved in AML-CFT work since 2007, when the legislation was first being shaped, he is widely regarded as New Zealand’s most experienced lawyer in this field.

Formerly a partner in a leading litigation law firm, Gary has over 20 years experience in NZ and the UK helping clients resolve compliance issues or investigations by regulators and government agencies. Areas of expertise include AML, Competition law, cartels, consumer protection, fraud, insurance law, privacy, anti-corruption, and financial services/banking regulation cases. Rankings by leading international lawyer guides (eg Chambers Asia-Pacific, Who’s Who Legal) include in areas of Competition law, Insurance, and Regulatory Investigations.

Gary has advised or represented a wide range of reporting entities, from large multi-national banks to small domestic lenders or global remittance businesses and, on occasion, a Supervisor or law firms. He regularly presents or publishes in his core practice areas, and through his website


Kylie Oliver

Kylie Oliver, CAMS
Chapter Advisory Board Member

Kylie Oliver is Manager Sanctions Compliance in ANZ’s Enterprise Financial Crime Team located in Melbourne. The role is responsible for policy development and monitoring of compliance with Economic and Trade Sanctions legislation across thirty countries.

A Financial Crime Professional, Kylie has over 10 years experience, most recently leading Financial Intelligence operations overseeing teams based in Melbourne, Bangalore and Manila.

Kylie has spent more than 25 years in the banking and finance arena, across a number of different business units in a wide range of roles including risk, operations and project management, training & development and change & communication. Kylie has worked in Australia, London and the Channel Islands for international banks including ANZ, Grindlays Private Bank and Standard Chartered Bank.

Kylie’s current role at ANZ’s requires a great degree of stakeholder management, engaging with business, risk and legal stakeholders to ensure that Financial Crime policies, procedures and guidelines strike the right balance between risk and commercial considerations.

Kylie holds a Masters of Business Administration (Deakin) and Bachelors of Training and Development (Melbourne). She is also a Certified Anti-Money Laundering Specialist (CAMS).


Working Group Members

Paula Milne (ANZ)
Sam Copeland (KPMG)

Julie-Anne Coghlan, CAMS (Flight Centre)

Ellen Szeto, CAMS (ANZ)
Kylie Oliver, CAMS (ANZ)
Manmohan Toshniwal, CAMS (ANZ)
Laura Burgess (NAB)

Calling for Expression of Interest. Email

Sophia Foo, CAMS (Rodger Reidy)
Mirza Baig, CAMS (Rabobank)
Geraldine Mangrai (Macquarie)
Vivian Tan, CAMS (Rodger Reidy)

Geoff Brown, CAMS (FMA)