Regulation Asia on 28th October reported that a new Bill has been introduced into the federal parliament which would allow entities to rely on CDD procedures performed by a third party.  At the same time, another Bill that limits cash payments to A$10,000 has passed through the lower house of the parliament.  The new Bill includes proposed reforms that are said to focus on streamlining obligations, lowering the regulatory burden where possible and improving compliance with international standards.  It also explicitly prohibits reporting entities from providing a designated service if customer identification procedures cannot be performed.  It prohibits financial institutions from entering into correspondent banking relationships with financial institutions that do business with so-called “shell bank”, and requires due diligence assessments to be conducted before entering, and during, all correspondent banking relationships, and it allows reporting entities to share suspicious matter reports and related information with external auditors, and foreign members of corporate and designated business groups.

An explanatory brief on the new Bill is available –

This blog is primarily for my own use, to keep informed and up to date. However, if you would like to say thank you (and perhaps help me get a new, better laptop when I am away…) you can “buy me a coffee” at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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