AML/CFT FAQs

Commonly Asked Questions

SOF/SOW is not determined by any particular value but rather it is risk based and also mandatory when conducting Enhanced Due Diligence (refer to S22 of the AML/CFT Act).

There is an obligation to file a Prescribed Transaction Report (PTR) for any cash transactions over $10,000.00 or more via the Police FIU goAML system. I assume this is where the confusion comes in.

No!

All reporting entities have an obligation to prepare an Annual AML/CFT Report covering the 12-month period from 1 July to 30 June. The Annual Report is of their firm’s Risk Assessment and AML/CFT Programme (aka Compliance Programme).

Every firm requires an EXTERNAL auditor to audit their firm’s compliance to the AML/CFT Act every two years (to be changed to every three years once the new regulations come into force – read here).

Yes!

The AML/CFT Act requires that an independent audit is conducted by an external auditor every two years (to be changed to three years).

An external audit is different to an internal audit.

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