AUSTRALIA Trends and Developments Contributed by: William Moore, Frank Hinoporos, Emma Woolley and Todd Bromwich, Hall & Wilcox
structures, including lawyers, accountants and real estate agents, are classified as reporting entities under the AML/CTF regime. This means they must imple - ment AML/CTF programmes, conduct customer due diligence (CDD) and report suspicious transactions, which directly affects how private wealth is struc - tured and managed. Reporting entities are required to establish source of funds and source of wealth infor - mation in certain circumstances, particularly as part of enhanced CDD where higher money laundering or terrorism financing risks are identified.
High net worth individuals acquiring assets such as real estate, establishing trusts or companies, imple - menting asset-holding structures, or undertaking succession planning may be subject to enhanced customer identification and verification requirements. They may also be required to maintain and provide detailed ownership records, including beneficial own - ership information for complex structures, together with supporting documentation. Early preparation and maintaining up-to-date records will be critical to minimise delays, particularly in time-sensitive trans - actions.
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