AML/CTF Policy

Introduction

Averillaw Solicitors is committed to preventing money laundering and the financing of terrorism through the provision of legal services. This Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Program and Policy outline our commitment to compliance with relevant laws and regulations, including the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act) and associated regulations.

Purpose

The purpose of this AML/CTF Program and Policy is to:

  • Establish and maintain effective systems and controls to prevent money laundering and terrorism financing activities.
  • Identify and mitigate the risks associated with money laundering and terrorism financing within the legal services provided by the firm.
  • Ensure compliance with all relevant AML/CTF laws, regulations, and obligations.
  • Provide ongoing training and awareness to staff members regarding their responsibilities in preventing money laundering and terrorism financing.

Risk Assessment

Averillaw Solicitors conducts regular risk assessments to identify and assess the risks associated with money laundering and terrorism financing within our legal services. This includes:

  • Assessing the nature of our clients, including their background, business activities, and geographic location.
  • Evaluating the potential risk associated with different types of legal services provided, such as conveyancing, immigration law, and wills and estates.
  • Identifying high-risk jurisdictions and industries where money laundering and terrorism financing activities may be more prevalent.

Customer Due Diligence (CDD)

We implement robust customer due diligence procedures to verify the identity of our clients and understand the nature of their legal matters. This includes:

  • Obtaining identification documents from clients, such as passports, driver's licenses, and utility bills.
  • Conducting enhanced due diligence for high-risk clients, including politically exposed persons (PEPs) and clients from high-risk jurisdictions.
  • Monitoring client transactions and activities for any suspicious or unusual behaviour.

Reporting Obligations

Averillaw Solicitors has reporting obligations under the AML/CTF Act to report any suspicious matters or transactions to the appropriate authorities. This includes:

  • Reporting suspicious matters to the Australian Transaction Reports and Analysis Centre (AUSTRAC) in accordance with the reporting requirements outlined in the AML/CTF Act.
  • Cooperating with law enforcement agencies and regulatory authorities in investigations related to money laundering and terrorism financing.

     

    Training and Awareness

    We provide ongoing training and awareness programs to ensure that all staff members are aware of their responsibilities in preventing money laundering and terrorism financing. This includes:

    • Providing training on relevant AML/CTF laws, regulations, and obligations.
    • Conducting regular updates and refresher training sessions to keep staff members informed of any changes to AML/CTF requirements.
    • Encouraging staff members to report any suspicious activities or concerns to the designated compliance officer.

    Compliance Monitoring and Review

    Averillaw Solicitors conducts regular compliance monitoring and reviews to assess the effectiveness of our AML/CTF Program and Policy. This includes:

    • Reviewing and updating our risk assessments and customer due diligence procedures as necessary.
    • Conducting internal audits and assessments to identify any areas of non-compliance or weakness in our AML/CTF controls.
    • Implementing remedial actions and improvements based on the findings of compliance monitoring and reviews.

    Governance and Oversight

    Our AML/CTF Program and Policy are governed and overseen by senior management and the designated compliance officer. This includes:

    • Establishing clear lines of responsibility and accountability for AML/CTF compliance.
    • Regularly reviewing and approving the AML/CTF Program and Policy to ensure alignment with regulatory requirements and best practices.
    • Providing adequate resources and support to facilitate effective AML/CTF compliance throughout the organization.

    Confidentiality and Data Protection

    Averillaw Solicitors maintains strict confidentiality and data protection measures to safeguard the information collected during the course of our AML/CTF activities. This includes:

    • Limiting access to sensitive information to authorized personnel only.
    • Implementing secure storage and transmission protocols for client data and documentation.
    • Complying with all relevant privacy laws and regulations when handling client information.

    Conclusion

    Averillaw Solicitors is committed to maintaining the highest standards of integrity, professionalism, and compliance with AML/CTF laws and regulations. Our AML/CTF Program and Policy are designed to mitigate the risks associated with money laundering and terrorism financing activities and ensure the integrity of our legal services.

    This AML/CTF Program and Policy outline our firm's commitment to preventing money laundering and terrorism financing through robust systems, controls, and compliance measures.

    Date: 1 July 2025