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Submitted URL: https://bt.com.au/fincrime
Effective URL: https://www.bt.com.au/professional/support/support-resources/financial-crime.html
Submission: On June 04 via manual from IN — Scanned from AU

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FINANCIAL CRIME


FINANCIAL CRIME IS A VERY REAL RISK FOR ANYONE WHO OWNS OR OPERATES A BUSINESS.
AND IT CAN HAVE DEVASTATING IMPACT ON CUSTOMERS AND COMMUNITIES. A RECENT PWC
STUDY FOUND THAT 35% OF RESPONDENTS HAD EXPERIENCED FRAUD IN THE LAST TWO
YEARS1.


We are aware of an active scam where individuals are impersonating BT staff
members and contacting investors offering investment into BT products.
BT will never make an unsolicited call to offer a product. If you receive a
suspicious call or communication, please contact your financial adviser and BT
immediately.




BT IS COMMITTED TO REDUCING THE RISK OF FINANCIAL CRIME ON THE BUSINESSES AND
CLIENTS WHO USE OUR PRODUCTS AND SERVICES.

Anti-Money Laun­der­ing


ANTI-MONEY LAUNDERING AND COUNTER-TERRORISM FINANCING (AML/ CTF) ATTESTATION

Iden­ti­fi­ca­tion icon


APPLICABLE CUSTOMER IDENTIFICATION PROCEDURES (ACIP) REVIEWS

Iden­ti­fi­ca­tion icon


IDEN­TI­FI­CA­TION REQUIREMENTS FOR ALL LICENSEE STAFF








ANTI-MONEY LAUNDERING AND COUNTER-TERRORISM FINANCING (AML/CTF) ATTESTATION

When distributing our products and services, we rely on Licensees to complete
and retain the applicable customer identification procedure under Part 7.2 of
the AML/CTF Rules. To support our AML/CTF program, BT asks Licensees to complete
a short AML/ CTF Attestation every one to two years. Licensees will be contacted
by email when it’s time to complete an AML/CTF Attestation (the ‘Attestation’).


BT can provide guidance on the AML/CTF Attestation process, but we can’t provide
advice on how to answer the questions. 


HOW TO COMPLETE AN AML/CTF ATTESTATION

 1. You will receive an email from BT’s Licensee Governance team requesting
    completion of the AML/CTF Attestation.
 2. Download AML/ CTF Attestation form from this page.
 3. Complete all questions on the AML/ CTF Attestation. For more information on
    each question, please read our AML/ CTF Attestation Support Guide.
 4. Email a copy to the Licensee Governance team at
    licenseegovernance@btfinancialgroup.com within 5 business days from
    receiving the email request.




AML/CTF FREQUENTLY ASKED QUESTIONS


1. HOW LONG DO WE HAVE TO COMPLETE THE AML/CTF ATTESTATION?




In line with the Terms and Con­di­tions of the Plat­form User Agree­ment
en­tered into by the Li­censee, the AML/ CTF At­tes­ta­tion must be re­turned
within 5 busi­ness days af­ter re­ceiv­ing no­tice to com­plete it.


2. WHAT QUESTIONS DO YOU ASK IN THE AML/CTF ATTESTATION?




The AML/ CTF At­tes­ta­tion will ask you 9 mul­ti­ple choice ques­tions about
your Li­censee’s ap­proach to com­ply­ing with your AML/ CTF oblig­a­tions. For
more in­for­ma­tion on the ques­tions and how they re­late to the AML/ CTF Act
2006, please read the AML/ CTF At­tes­ta­tion Sup­port Guide.

 


3. DO I HAVE TO COMPLETE THE AML/CTF ATTESTATION?




Yes, AML/ CTF com­pli­ance oblig­a­tions are out­lined in the Plat­form User
Agree­ment in place be­tween BT and the Li­censee, and com­ple­tion of the AML/
CTF At­tes­ta­tion is a manda­tory re­quire­ment.


4. I’M NOT SURE HOW TO ANSWER ONE OF THE QUESTIONS?




In the first in­stance, we rec­om­mend you re­fer to your Li­censee’s
com­pli­ance rep­re­sen­ta­tive. If you’re still un­sure, you can read our AML/
CTF At­tes­ta­tion Sup­port Guide or con­tact the Li­censee Gov­er­nance team on
li­censee­gov­er­nance@bt­fi­an­n­cial­group.com.


5. WHO SHOULD COMPLETE THE AML/CTF ATTESTATION?




The com­pli­ance rep­re­sen­ta­tive in your Li­censee is the most ap­pro­pri­ate
per­son to com­plete the AML/ CTF At­tes­ta­tion. If we don’t have the cor­rect
de­tails for the com­pli­ance rep­re­sen­ta­tive for the Li­censee, please email
their con­tact de­tails to li­censee­gov­er­nance@bt­fi­nan­cial­group.com, so
we can en­sure we con­tact the cor­rect per­son.   


6. HOW CAN BT HELP YOU WITH COMPLETING THE ATTESTATION?




BT can pro­vide guid­ance on AML/ CTF At­tes­ta­tion process, but we can’t
pro­vide you ad­vice on how to an­swer the ques­tions.  

If you’re un­sure of the steps you need to take, please con­tact the Li­censee
Gov­er­nance team at li­censee­gov­er­nance@bt­fi­nan­cial­group.com — they’d be
happy to help.


7. WHAT HAPPENS IF I DON’T COMPLETE IT?




We will send you re­minders to com­plete the AML/ CTF At­tes­ta­tion. If we
don’t hear from you, we’ll need to take fur­ther ac­tion — and you may not be
able to use the Plat­form.


8. I HAVE COMPLETED THE AML/CTF ATTESTATION. WHAT HAPPENS NOW?




Once you have com­pleted the AML/ CTF At­tes­ta­tion and sent it to the
Li­censee Gov­er­nance team on li­censee­gov­er­nance@bt­fi­an­n­cial­group.com,
we’ll send you an email to con­firm we have re­ceived it. Com­plet­ing an AML/
CTF At­tes­ta­tion is an on­go­ing com­pli­ance re­quire­ment, and the Li­censee
can ex­pect to be con­tacted again to com­plete an­other AML/ CTF
At­tes­ta­tion, in 1-2 years.




ACIP REVIEW

All authorised representatives of an AFS licensee must carry out and maintain a
record of the Applicable Customer Identification Procedure for each client, in
line with AML/CTF obligations.

BT undertake ACIP Reviews as an oversight measure, as part of our reliance on
third parties who use our products and services.



Play video
BT - Financial crime risk, and what we are doing about it (2:15)



COMPLETING AN ACIP REVIEW

En­ve­lope icon


YOU RECEIVE A REQUEST TO COMPLETE AN ACIP REVIEW

WE WILL SEND YOU A LIST OF RANDOMLY SELECTED CLIENTS, AND INFORMATION ON WHAT
IDV DOCUMENTS WE NEED FOR EACH CLIENT


Download our IDV requirements guide on what documentation should be sent to us


Doc­u­men­ta­tion icon


SEND BT THE IDV DOCUMENTATION

YOU CAN SEND THE DOCUMENTATION TO US VIA ENCRYPTED EMAIL USING SOFTWARE OF YOUR
CHOICE, OR FILESHARE.


Download our Data protection guide on how to send the documentation
electronically

Per­son icon


IDV DOCUMENTS ARE REVIEWED

A MEMBER OF THE LICENSEE GOVERNANCE TEAM WILL REVIEW THE DOCUMENTATION YOU SENT
TO US


Allow 10 business days for the review to be completed

Tick icon


REQUEST COMPLETED

We’ll send you confirmation that your ACIP Review has been completed.





ACIP FREQUENTLY ASKED QUESTIONS


1. HOW OFTEN WILL I NEED TO COMPLETE AN ACIP REVIEW?




ACIP Re­views are a re­liance mea­sure we have put in place, that we will ask of
you with no set time­frame. How­ever, we ex­pect you won’t gen­er­ally be asked
to com­plete it more than once every 2 years, un­less a spe­cific event oc­curs.



2. WILL THE LICENSEE BE ASKED TO DO A ACIP REVIEW AND AML/CTF ATTESTATION AT THE
SAME TIME?




Yes, it is pos­si­ble, but you won’t gen­er­ally be asked to com­plete both at
the same time.


3. HOW LONG DO WE HAVE TO COMPLETE THESE REQUIREMENTS?




In line with the Terms and Con­di­tions of your plat­form user agree­ment, the
ACIP Re­view needs to be com­pleted within 5 busi­ness days af­ter re­ceiv­ing
no­tice to com­plete it.


4. CAN WE GET AN EXTENSION TO COMPLETE IT?




Ex­ten­sions will gen­er­ally only be granted un­der ex­cep­tional
cir­cum­stances. If you need more time to com­plete the ACIP Re­view, please
speak to one of the Li­censee Gov­er­nance team mem­bers.  

The AML/ CTF leg­is­la­tion re­quires a Li­censee to pro­vide an ‘im­me­di­ate
re­spon­se’ to re­quests of this na­ture. Our User Agree­ment al­lows up to 5
busi­ness days.


5. WILL I NEED TO DO THIS FOR EACH BT PLATFORM I HAVE?




Yes. Both plat­forms will be con­sid­ered for ACIP Re­views, and the client
sam­ples will be across As­gard and Panorama.


6. IF THE AML/CTF ACT HAS BEEN IN PLACE SINCE 2006, WHY IS THIS HAPPENING NOW?




Like any Com­mon­wealth leg­is­la­tion, the AML/ CTF Act is un­der con­stant
re­view to en­sure it re­mains con­tem­po­rary, ef­fec­tive and meets its
ob­jec­tives – for AML/ CTF, the leg­isla­tive ob­jec­tives are en­shrined in
law and, sup­ports con­fi­dence in the Aus­tralian fi­nan­cial sys­tem by
in­tro­duc­ing mea­sures to de­tect, de­ter and dis­rupt fi­nan­cial crimes. 

These lat­est amend­ments to the AML/ CTF Act be­came law in June 2021 and the
in­dus­try con­tin­ues to adapt to the new re­quire­ments. And the
leg­is­la­tion will con­tinue to be en­hanced to re­spond to global
de­vel­op­ments and ex­pec­ta­tions in fi­nan­cial crime


7. WHAT DOCUMENTATION FOR MY CLIENTS DO I NEED TO PROVIDE?




The doc­u­men­ta­tion for each client will be dif­fer­ent de­pend­ing on what
type of ac­count they have with you. Please read our IDV re­quire­ments guide
for more in­for­ma­tion.



8. HOW DO I SEND THE DOCUMENTATION TO BT?




You can send the doc­u­men­ta­tion to us via en­crypted email us­ing the
soft­ware of your choice, or File­share. In­struc­tions on how to do ei­ther
op­tion are out­lined in the Data pro­tec­tion guide.





ACIP HINTS AND TIPS

FindingsDescriptionWhat you can do Your client’s middle name is missing

A common issue found during the ACIP review process is the client’s middle names
isn’t captured in the BT system during the onboarding process. This can also
include the full name not being collected by the adviser on an FSC form (or
equivalent).

When onboarding future clients, please ensure their full name is entered
correctly, including their middle name (if they have one), so the information
matches during the ACIP Review.

Incorrect identification documentation for client on file

As part of the ACIP review process you’ll need to provide BT with copies of the
applicable identification documents that were used to collect information about
your client at the time of onboarding, or from the date a designated service was
provided.

Depending on the date the account was onboarded, the identification documents
held on record may now be expired, but the expiry date will still match what was
captured in the BT system at the time the account was setup.

By law, you’re required to ‘keep customer identification procedure records for
the duration of your relationship with the customer, and for an additional seven
years after you stop providing any designated services to them.’

When providing copies of the identification documents to BT for your ACIP
Review, please ensure you send us the documents you used at the time of
onboarding, or when the designated service period began.

Keying errors

During the online account onboarding process, keying errors can be a common
occurrence when an adviser completes the input of their client’s identification
details i.e. driver’s license/ passport numbers and expiry dates.

Ensure you take extra care when capturing your client’s identification details
during the onboarding process, to minimise any errors that arise during the ACIP
Review.




IDENTIFICATION REQUIREMENTS FOR ALL LICENSEE STAFF

To protect the security of client accounts held with us, we require all Asgard
and Panorama users who act as an ‘agent of a customer’, including advisers,
paraplanners and support staff to complete identification and financial crime
screening. Agents should provide us with their residential address, date of
birth and other information as ID, as part of our agent onboarding process.




1 Source: PWC Fighting Fraud- A familiar foe in unfamiliar times report
pwc-gecs-2020-au-report.pdf


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