External advice/consultants $2,000 12 $24,000 $4,000 4 $16,000 ONGOING Threshold transaction reports - - - Submit the suspicious matter report (SMR) to AUSTRAC 2 per SMR x 60 SMRs per entity per annum (TOTAL = 120 hours) 16 1920 hours per annum Industry has indicated that they would report approximately 60 SMRs per annum. Completing the SMR process would take a maximum of 0.5 hours. Compliance Report and updates to AML/CTF program - - - AUSTRAC Compliance Audit 5 hours per entity per annum 2 10 hours per annum Based on the size of the sector, AUSTRAC would conduct compliance assessments of no more than 2 providers per annum. CDD obligations: 6000 new customers per annum per entity x $3.50 per individual search using providers (TOTAL = $21,000) 4 $84, 000 per annum are currently 12 businesses operating as a digital currency exchange and identifying their customers using e-verification processes. These businesses have chosen to adopt these measures as part of their fraud prevention, readiness for AML/CTF compliance and also to provide assurance to the banks that the providers are adopting appropriate measures to mitigate fraud, sanctions and other risks. Confirmed 12 digital currency businesses operate a fully digital model and already conduct CDD using e-verification processes. verification
Costs to the customer to provide CDD information 24,000 new customers affected per annum x 0.05 hours (3 mins) per customer. (TOTAL: 1200 hours) 10% of all new customers (4,800 new customers) x 0.16 (10 minutes) (TOTAL: 768 hours) E-verification: $37,200 Follow up processes: $23,808 TOTAL: $61,008 As per option 2. DEREGULATION OF THE CIT SECTOR – OFFSET TOTAL: ($326,414,010) Item Savings Number of affected entities Total Justification CAPITAL SAVINGS Understand AML/CTF Obligations - - - - - - Register - - - Program development - - - IT Upgrades - - -
DESIGNATED BUSINESS GROUPS - OFFSET ($39,875,499) Item Savings Number of affected entities Total Justification ONGOING SAVINGS Cost saving for identifying and analysing a suspicious matters & submitting an SMR to AUSTRAC 2,366 SMRs submitted by REs within an existing DBG x 14 hours (TOTAL: 33,124 hours) Reporting entities that formed more than one DBG (banking and finance sector) 33,124 hours per annum 78,876 suspicious matter reports were submitted to AUSTRAC in 2015-16. It is assumed that 3% of SMRs were submitted by reporting entities that formed more than one DBG and therefore submitted duplicate reports for the same customer. It is assumed that forming a suspicion either manually or via an alert and also the process of investigating an SMR may take on average 14 hours to complete. CUSTOMER SAVINGS Neutral Deregulating insurance intermediaries and general insurance providers under the FTR Act – OFFSET $555,886
OXFAM 24 September 2015 Gaming sector: Gaming machines Australian Hotels Association ClubsNSW Mercury Victoria Inc ALH Group Pty Ltd Gaming sector: Casinos Casinos and Resorts Australasia Gaming sector: Wagering Australian Wagering Council Australian Bookmakers Association Limited TattsGroup Cash-in-transit sector Australian Security Industry Association Limited Linfox Armaguard Prosegur 25 September 2015 Remittance sector: Large remitters Western Union Remittance sector: Small/medium remitters UAE Exchange Hai Ha MoneyGram OzForex RIA 26 September 2015 AML compliance sector AML Master 2 October 2015 AML compliance sector Yarra Valley Associates 25 November 2015 Banking sector: Australian Finance Conference