Frequently Asked Questions
Compliance and Professional Standards – February 2008
The following provides you with frequently asked questions from advisers in relation to Anti-Money
Laundering / Counter Terrorism Finance (“AML/CTF) requirements.
Further information can be found within RetireInvest’s Anti-Money Laundering/Counter Terrorism Finance
(“AML/CTF”) Operational Policy located on the Adviser Services Website. If you have any questions, please
contact a member of the Compliance and Professional Standards Team.
Question: Will AML/CTF requirements be incorporated into the Compliance Review Program?
Response: As part of RetireInvest’s Compliance Review Program, Compliance Development Managers will
be assessing compliance with the AML/CTF professional standards set out in this professional standard. This
will be assessed via the “Compliance Review Checklist.”
Non-compliance with respect to AML/CTF professional standard will deem the compliance review for the
particular client file to be “unsatisfactory,” and an incident will be reported by RetireInvest.
Question: Under AML/CTF legislation, what are my requirements?
Response: RetireInvest Advisers have two main obligations under the AML/CTF Act:
(a) To identify and verify all new and existing customers prior to arranging for the customer to
receive a designated service.
(b) To maintain appropriate records of customer identification procedures.
To comply with the AML/CTF Act, Advisers will need to carry out customer identification and verification prior
to the time that they arrange for the relevant designated service (i.e. generally this means when the
completion of a product provider’s application form is undertaken) irrespective of whether they are a new or
existing customer of the Adviser.
Question: For what services do I trigger the identification and verification requirements?
Response: You will need to undertake the appropriate identification and verification procedures where you
arrange for a client to:
• Obtain or be issued with new or additional interests/units in a managed investment scheme
• Open or make a deposit for a cash management trust
• Buy/sell shares/options in a listed company or trust
• Pay a premium or be issued with an investment life insurance policy as follows:
• Regular premium policy: with an annual premium greater than $1,500; or
• Single premium policy: with a single premium greater than $3,000
• Obtain or be issued with an annuity
• Obtain or be issued with a pension
• Obtain an interest in or have the ability to transact through WRAP/Platform/IDPS
• Cash out all or part of a superannuation interest.
The implementation of the following financial services is not caught under the AML/CTF Act:
• Obtaining or being issued with a new superannuation fund or making additional contributions
to a superannuation fund.
• Purchasing personal insurance (where no investment component exists within the policy)
such as Life, TPD, Trauma and Income Protection Insurance.
Question: At what point in the advice process do I need to undertake the identification and verification
Response: Where a “designated service” is provided, Advisers will need to carry out customer identification
and verification prior to the time that they arrange for the relevant designated service - i.e. generally this
means when the completion of a product provider’s application form is undertaken. Advisers are free to
undertake the identification and verification procedure earlier if they wish (that is, at any point in time after the
privacy statement has been signed off within the fact find).
If you prepare an Advice Document but the client decides not to implement the recommendation (of the
“designated service”), you are not required to undertake the identification and verification procedures.
Question: From my understanding, the AML/CTF Act identifies different customer types. Does each type
have different identification and verification requirements?
Response: That’s right. The AML/CTF Act does identify 8 different customer types and each has differing
identification and verification requirements.
The 8 different customer-types are:
1. Individuals 5. Incorporated associations
2. Companies 6. Unincorporated associations
3. Customers acting in the capacity of a 7. Registered co-operatives
trustee of a trust 8. Government bodies
4. Customers acting in the capacity of a
member of a partnership
Question: What do I need to do in order to satisfy the identification and verification requirements?
Response: RetireInvest has chosen to use the IFSA/FPA Customer Identification Forms for the above listed
customer-types. Advisers are required to complete the appropriate IFSA/FPA Customer Identification Form
IFSA/FPA which will ask you to obtain an original copy of identification, or a certified copy. The IFSA/FPA
Customer Identification Forms can be found on the Adviser Services Website.
You should then keep a “master copy” of the IFSA/FPA Customer Identification Form and identification
(either a copy of an original or a certified copy) within your client’s file. Copies of these should then be
provided to product providers. This will mean that you will always maintain a copy of the relevant
documentation within your client’s file.
Question: For individual clients, do I need to worry about completing a “100 point check?”
Response: The AML/CTF Act does not make any reference to a “100 point check” for individual clients.
Instead you are required to meet primary or secondary identification requirements. Basically, if you obtain an
original or a certified copy of a primary document (i.e. driver’s licence, Australian passport, etc) and you
complete the IFSA/FPA Customer Identification Form, you will satisfy the requirements. The IFSA/FPA
Customer Identification Form for individuals provides further details.
Keep in mind though; some products (e.g. banking products) may require a “100 point check” to be
completed in addition to AML/CTF requirements. This should be done in addition to your AML/CTF
Question: For individual clients, what are “primary” and “secondary” identification?
Response: The IFSA/FPA Customer Identification Form for individuals will outline what is acceptable primary
and secondary identification. “Secondary” identification should only be conducted where:
• “Primary” identification is unable to be conducted; or
• The Adviser forms the view that a discrepancy arose from the information collected and
verified using “primary” identification; or
• Having conducted “primary” identification, the Adviser is not reasonably satisfied that the
customer is the individual he or she claims to be.
Primary identification consists of either a: driver’s licence; passport (up to 2 years expiration is acceptable);
card issued under state or territory for the purpose of proving a person’s age (containing a photograph); or a
foreign passport (containing a photograph and signature).
Question: For individual clients, is copying their driver’s licence enough?
Response: As long as you have completed the IFSA/FPA Customer Identification Form for individuals,
obtaining a copy your client’s current driver’s licence is enough to meet the identification and verification
requirement’s as it is a form of “primary” identification.
Question: For individual clients, is a card issued by Centrelink as well as a utilities tax invoice (e.g. electricity,
gas, etc) enough?
Response: As long as you have completed the IFSA/FPA Customer Identification Form for individuals, and
the client is not able to provide a “primary” identification, the above is adequate as it satisfies “secondary”
Question: Do I have to complete the appropriate identification and verification for both a husband and wife?
Response: Where you arrange to provide a designated service for both a husband and wife, you will be
required to complete an IFSA/FPA Customer Identification Form and obtain appropriate identification for
Question: What do I need to do if a client has a Power of Attorney looking after their affairs?
Response: In the case of a client having a Power of Attorney looking after their affairs, you are required to
conduct the same process as if the Power of Attorney was the client. This means that you are required to
complete the IFSA/FPA Customer Identification Form for individuals on the Power of Attorney, and obtain
appropriate identification as outlined on the IFSA/FPA Customer Identification Form.
The same process would also need to be complete for the client. Further to this, you are required to obtain
evidence of the Power of Attorney’s authority to act on behalf of the client (e.g. a signed Power of Attorney).
Be aware, product providers may request a copy of this.
Question: What should I do for remote clients?
Response: When dealing with remote clients, you will need to obtain certified copies of appropriate
identification, and follow the applicable identification and verification procedure outlined throughout this
professional standard. You must not proceed with any transaction until such time as you have conducted,
and are in receipt of, appropriate identification from your client.
Question: When do I need to update the customer identification I have within my client’s file? What if my
client’s address has changed – do I need to obtain updated identification to reflect this.
Response: At any time that you arrange for the provision of a “designated service”, your obligation is to take
reasonable steps to ensure that the customer details recorded are current and you should update your
records where you are aware that customer details have changed.
Question: If I have reason to doubt who my client claims to be, what do I need to do?
Response: Where you have reason to doubt that customer is the person they claim to be, you should
undertake the “secondary” identification process in addition to the “primary.” You are also required to notify
the National Manager of Compliance and Professional Standards as soon as possible.
Question: What will happen if a product provider has reason to doubt the identity of a customer?
Response: Where a product provider has reason to doubt the identity of a customer, they will approach you
for assistance. You should then advise the product provider of the course of action you intend to take
including the time frame of any re-identification procedure (this may mean undertaking the “secondary”
You should assist the product provider at all times. Due to prohibitions under the AML/CTF Act, the product
provider is generally not permitted to advise you of the reasons for the need to re-identify a customer
Question: What records do I need to maintain?
Response: You have an obligation to maintain a copy of the IFSA/FPA Customer Identification Form and a
copy of the identifications conducted.
Question: What records do I have to provide product providers?
Response: A product provider will require you to either provide a copy of the IFSA/FPA Customer
Identification Form that you have competed, or complete their own customer identification form/checklists.
This, in addition to attaching a copy of identification obtained from the customer will satisfy the requirements
of product providers. You must comply with any request made by a product provider.