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Submission: Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Amendment Bill 2024

Transparency International Australia (TI Australia) is pleased to provide the following comments and recommendations to the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Amendment Bill 2024 to address the key gaps in Australia's money laundering regime.

TI Australia has long called for updates to the regime that will close the loopholes that allow people to hide the proceeds of crime and corruption. An essential element of the update is the inclusion of designated non-financial businesses and professions (DNFBPs) and high value dealers in the AML/CTF regime. Australia is one of only a few FATF countries not to have passed tranche-two amendments to AML/CTF laws, along with Haiti, Madagascar, China and the United States.

TI Australia provided recommendations in successive rounds of consultation in 2023 and 2024 with government on the proposed changes. We include a link to our recent submission to the Attorney General's second round consultation into modernising Australia's AML/CTF regime. We are reiterating the recommendations previously shared because they are essential for the effectiveness of the AML/CTF regime and must be included in the eventual Bill. We have highlighted the following themes as particularly relevant to this inquiry: beneficial ownership transparency, legal professional privilege, responsibility of Tranche 2 entities, and effectiveness.

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