Anti Money Laundering (AML) Update December 2009
What do Brokers need to do to comply with the AML/CTF Act?
The Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act) was introduced to help
detect and prevent money laundering and the threat to national security caused by the financing of terrorism.
The “ING DIRECT Customer Identification Procedures for Brokers” are available on the Introducer Website
and detail what must be adhered to when you are acting on behalf of ING DIRECT.
Customer Identification & Verification
The objective of the identification procedure is to determine that the customer is the person or entity they claim
to be. Some key points to remember:
For all loans:
o ING DIRECT may instruct you to collect additional information from the customer. These additional
requirements will become general conditions required before the loan can proceed to full approval.
o It is also important the Application Form, Identification Form, Verifying your Identity Form and/or the
Company & Trust Appendix are correctly completed and signed.
o Any documents written in a language that is not English must be accompanied by an English translation
prepared by an accredited translator.
o You must sight and copy two original identification documents.
o If you cannot identify the customer face to face they may be identified by using the Verifying Your Identity
Form and having copies of their identification documents certified.
o A copy of the identification documents need to be provide to ING DIRECT.
For Companies & Trusts
o It is your responsibility to ensure all Director’s, Trustee’s, guarantors and authorised signatories who will
have access to the loan are identified.
o You must obtain from the customer the original or a certified copy of the Trust Deed and provide a copy to
Suspicious Matter Reporting
Brokers are in some cases best equipped to identify suspicious matters on behalf of ING DIRECT. ING
DIRECT has an obligation to report certain suspicious matters to AUSTRAC within three days of a suspicion
being formed or within 24 hours if the suspicion relates to the financing of terrorism. Suspicious matters must
be reported even if the loan transaction or account does not proceed.
Some examples of unusual client activity, also known as suspicious matters:
o The customer (or their agent) is not who they claim to be
o An individual with discrepancies between their identification documentation;
o An individual who presents seemingly false identification;
o Any use of false names;
o An individual with a variety of similar, but different, addresses;
o An individual who requests to be anonymous and makes unusual requests or wishes to disguise their
purpose for requesting the loan
o The clients’ occupation, business and known circumstances do not correlate with the services requested
or the volume of funds available.
o The client has an unusually high accumulation of assets for his / her means without reasonable
o The client‘s transactional activity is inordinate compared to other clients of similar profiles and means.
If you suspect that a client may be using financial products or services in connection with criminal activity
(including tax evasion, terrorist financing or money laundering):
o Report your suspicion to ING DIRECT immediately
o Do not confront or tell the client or refuse the client normal service.
o Do not otherwise alert the client to your suspicions. This is known as “Tipping Off” and is an offence.
How do I keep up to date with AML?
ING DIRECT recognises that the MFAA, FBAA and FPA periodically offer AML/CTF training refreshers as part
of their continuing professional development (CPD) programs. We encourage all brokers to complete the
AML/CTF training refreshers offered by the Industry Association that they belong to.
ING DIRECT will also publish a newsletter similar to this on an annual cycle to keep you abreast of your
Where do I go to get clarification on an AML/CTF question?
Your first point of contact is the Introducer Website. Please check for updates. You can also contact your
Business Development Manager.