Anti-Money Laundering and Counter-Terrorism Financing Program
The Australian Government introduced the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Act 2006 in response to global pressures to strengthen Australia's ability to detect and prevent money laundering and terrorism financing.
Suncorp takes the implementation of the AML/CTF Act seriously and has taken steps to ensure that we meet our obligations as set out in the AML/CTF Act and the AML/CTF Rules.
Current legislation for money laundering and terrorism financing includes:
- Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Act 2006;
- Proceeds of Crime Act 2002;
- Suppression of the Financing of Terrorism Act 2002;
- Anti-Terrorism Act 2004;
- Anti-Terrorism Act (No. 2) 2005;
- Charter of the United Nations Act 1945.
Key components of Suncorp’s responsibilities in our Designated Business Group AML/CTF Program
Designated Business Group
Our Designated Business Group (DBG) includes a number of entities within the Suncorp Group that offer Designated Services (as defined in the AML/CTF Act). For details of which entities are members of the DBG, please contact Suncorp.
Oversight by Board and Senior Management
Suncorp's AML/CTF program has been approved at Board level and has ongoing oversight via Senior Management and Line of Business reporting structures.
AML/CTF Compliance Officer
Suncorp has appointed an AML/CTF Compliance Officer at management level who has the responsibility for the AML/CTF Program.
Suncorp has appropriate AML/CTF Risk Awareness Training in place to assist all affected staff to understand the obligations, the risks, the consequences of non-compliance and the procedures and processes in place. This training is undertaken on a recurring cycle or when legislative change dictates.
Employee Due Diligence
Suncorp has procedures and processes in place to ensure that employees have the appropriate background checks to mitigate the risk of using their position to facilitate money laundering or terrorism financing as well as ongoing control mechanisms.
Independent Review of our AML/CTF Program
Suncorp's AML/CTF Program is subject to independent reviews conducted by our Internal Audit department to assess the effectiveness of our risk based controls and ensure compliance with the AML/CTF Act and Rules. Frequency is risk based and determined on business requirements. Reports are provided through to Senior Management and the Audit Committee.
Suncorp has implemented processes and procedures to ensure that records made in respect of customer identification are held for 7 years after the end of the relationship. Other documentation will be retained for the length of time required to meet our legislative obligations.
Know your Customer
Suncorp introduced a risk based methodology based on the requirements of the AML/CTF Act and Rules to collect and verify certain information to confirm customer identities. In most cases, this will occur at the point of time of on boarding a new customer or entity. Controls, processes and procedures have been developed to capture this information based on Suncorp’s risk tolerance.
Suspicious Matter Reporting
Suncorp has implemented controls, processes and procedures to detect and report suspicious activities and transactions to AUSTRAC.
Suncorp is required to provide the regulator the following transaction details and has developed the controls, processes and procedure to submit:
- All inward and outward International Funds Transfer Instructions in the format as required by AUSTRAC
- All threshold transactions where the interaction involves cash amounts of $10,000.00 or more in the format required by AUSTRAC.
Suncorp has implemented controls and processes to monitor customers and transactions against prescribed lists to ensure that we do not knowingly participate in any transaction that facilitates terrorism financing or breaches Australian law.
Suncorp has implemented processes and procedures to ensure that we will:
- Not conduct business with shell banks
- Not offer pay through accounts
- Conduct regular due diligence reviews of our correspondent bankers to understand their AML/CTF policies and controls
Administrative Information for Correspondent Banking Due Diligence
Operating Banking Entity: Suncorp-Metway Ltd (Authorised Deposit-taking Institution)
Registered Address: Level 23, 80 Ann Street, Brisbane QLD 4000
Stock Exchange: Australian Stock Exchange (ASX)
Australian Transaction Reports and Analysis Centre (AUSTRAC) - Australia's AML/CTF regulator and Financial Intelligence Unit.
Australian Prudential Regulation Authority (APRA) - the prudential regulator of Australia's financial services industry.
Australian Securities and Investment Commission (ASIC) - the regulator for corporations, markets and financial services.
Please refer to the attached links.
Refer to our Annual Report per attached link:
AML/CTF Contact: AML/CTF Compliance Officer (4FI032)
GPO Box 1453 BRISBANE QLD 4001
For further information please email D&POpRisk&AML@suncorp.com.au
USA PATRIOT Act Certificate:
In accordance with the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (USA PATRIOT ACT) Act 2001, financial institutions in the United States are required to obtain certain undertakings and maintain certain records about banks outside the United States with whom they maintain correspondent accounts.
Suncorp-Metway Ltd ABN 66 010 831 722 (“Suncorp Bank”) has prepared a global certificate setting out this information. The Global Certificate is intended for use, and may be relied upon, by any financial institution requiring a USA PATRIOT ACT Certificate from Suncorp Bank.
Suncorp Bank is authorised by the Australian Prudential Regulation Authority (APRA) in Australia to carry out banking business in Australia.
If you have any questions, please submit an enquiry to D&POpRisk&AML@suncorp.com.au.
The AML/CTF Wolfsberg Questionnaire is available upon request. Please contact D&POpRisk&AML@suncorp.com.au for assistance