Anti-money laundering and counter-terrorism financing compliance statement
1. Administrative information
Legal name Cuscal Limited (Cuscal)
Principal place of business / Registered office Level 2, 1 Margaret Street, Sydney NSW 2000 Australia
Place of incorporation Sydney, Australia
Legal status Public limited company
Major shareholders Credit unions
Australian Financial Services Licence 244116
AML Compliance Officer Kieran McKenna
Level 2, 1 Margaret, Sydney NSW 2000, Australia
Phone 61 2 8299 9069 Fax 61 2 8299 9763 Email firstname.lastname@example.org
2. Senior management
3. Anti-money laundering and counter-terrorism financing measures at Cuscal
Cuscal is subject to, and complies with, Australian law. Australian laws applicable to Cuscal include:
- Anti-Money Laundering and Counter-terrorism Financing Act 2006 (AML/CTF Act)
- Corporations Act
- Proceeds of Crime Act 2002 and associated regulations
- Criminal Code Act 1995 and associated regulations
Under the AML/CTF Act AUSTRAC, the regulatory authority charged with oversight of the legislation, has made Rules relating to AML/CTF obligations. Cuscal has implemented the requirements of this Act and Rules and has adopted internal policies, procedures and controls to ensure ongoing compliance.
- Customer due diligence/know your customer
Cuscal has policies and procedures in place to comply with the obligation to identify customers as required by the AML/CTF Act.
- Record retention
Records relating to customer identification are maintained in Australia and kept for seven (7) years after the termination of services offered by Cuscal.
- Ongoing customer due diligence
Monitoring is carried out through a risk-based approach. Cuscal staff in the relevant roles receive periodic training and reminders of the requirement to monitor customers and their transactions on an ongoing basis.
- Reporting obligations
Cuscal is required to submit reports to AUSTRAC in relation to suspicious matters, threshold transactions and international fund transfer instructions.
- Suspicious matter Cuscal is required to report any suspicious matters connected to the actual or potential provision of a designated service.
- Threshold Transaction Reporting (TTR) Cuscal is required to report transactions involving the transfer of physical currency, or money in the form of e-currency, where the total amount is not less than $10,000. However, Cuscal does not process any cash transactions hence TTR requirements do not apply.
- International funds transfer instructions
Cuscal is required to report international wire transfers.
- Employee training program
Training is provided to business units that offer products and services that are subject to these legislative requirements. Cuscal staff impacted by the AML/CTF Act receive periodic training and reminders about the detection and reporting process for suspicious activities, customer identification procedures, ongoing due diligence and record keeping. Changes to AML/CTF legislation, or any emerging risks, are communicated to the relevant staff.
- Employee due diligence
Cuscal has processes and controls in place that provide reasonable assurance of the identity, honesty and integrity of prospective and existing employees.
- Agents of Cuscal
Agents of Cuscal are required to comply with relevant AML/CTF obligations it performs on Cuscal’s behalf. In complying with the AML/CTF Act, additional controls and assurance processes have been implemented to manage the risk of money laundering and the financing of terrorism.
- Independent review
Cuscal’s internal auditors (KPMG) conduct reviews and compliance testing of Cuscal’s policies and operational procedures related to its AML/CTF Program Part A. The results of the review are reported to senior management and actioned.
- Correspondent banks
Cuscal does not have any correspondent banking relationships.
- Shell banks
Cuscal does not conduct business with shell banks.
- Politically exposed persons (PEPs)
Cuscal’s risk-based approach considers PEPs to pose an increased risk for money laundering and the financing of terrorism . Internal policies and procedures are in place to ensure compliance with the applicable legislation and regulatory requirements.
- AML officer
Cuscal has designated an AML/CTF Compliance Officer at the appropriate management level. The contact for AML-related matters has been provided above.