In March, the Institute had its latest meeting with the Attorney General’s department, which is preparing the second tranche of anti-money laundering legislation. The Institute has been lobbying government on this issue since 2005. 
 
At present, the dialogue surrounds exactly which accounting services will be subject to new obligations under the legislation. The Institute supports the philosophy of the legislation (to prevent criminal activity and help stifle terrorist activity) but wants to ensure that only services which may present a risk will carry obligations. 
 
After the meeting, the Institute followed up with a letter to the Attorney General's department, and an outline of the key areas the government should consider. 
 
When the second tranche of legislation is finalised, the Institute will provide comprehensive support to help members meet their compliance obligations.  
 
What can members expect to see in the new legislation? 
The first tranche of legislation, which was passed in December 2006, affected the financial services sector. The government indicated that the obligations contained in the first tranche are likely to apply to second tranche designated services. The key obligations are to apply a risk-based approach to:

• Undertake 'customer due diligence' with ongoing monitoring
• Implement an program to identify, mitigate and manage money laundering/terrorist financing risk, which incorporates:
• Employee due diligence and training
• The appointment of a compliance officer
• Senior management oversight.
• Report on suspicious matters and compliance issues
• Document procedures and retain records for seven years.

• The Institute: anti-money laundering
• The Institute: letter to the Attorney General's department
• The Institute: outline of the key areas the government should consider