The Australian Transaction Reports and Analysis Center (AUSTRAC) developed “A guide to preparing and implementing an AML/CTF program for your digital currency exchange (DCE) service business”. It provides information for DCE services on whether they need to register with AUSTRAC, their AML/CTF obligations and some areas of considerations while preparing their AML/CTF programs.
The guide contains a comprehensive AML/CTF program checklist for digital currency exchanges. As per the checklist, DCEs should:
- Complete an ML/TF risk assessment of their business
- Design and adopt an AML/CFT risk awareness training program
- Design and adopt an employee due diligence program
- Formally adopt the AML/CTF program and subject it to ongoing oversight by senior management/board
- Appoint an AML/CTF compliance officer
- Subject AML/CTF program to regular independent reviews
- Describe procedures for responding to AUSTRAC feedback
- Describer their reporting procedures
- Set out procedures for keeping their AUSTRAC enrolment and registration details current
- Set out their procedures for ongoing customer due diligence, including transaction monitoring and their enhanced customer due diligence program
- Keep records
- Set out their procedures for collecting and verifying know your customer(KYC) information
It needs to be noted that while the checklist may assist in designing a holistic program, it does not ensure complete compliance. The guide also provides information on exemptions for some reporting entities and compliance to Australian sanctions laws. The respective sections provide links to relevant resources.