Despite a general belief across industry that submitting an SMR discharges their obligation to act on a suspicious customer, Australian law enforcement has recently expressed the view that this may not be enough. The AFP has indicated that Section 51 of the AML/CTF Act may not protect a reporting entity that held on to a customer they had been reporting as suspicious. Instead, a reporting entity may also need to end its relationship with the customer who continued to engage in suspicious activity.
|Number of pages||4|
|Journal||Anti-Money Laundering Magazine|
|Publication status||Published - 2011|