The credit checks centre around credit risk to APT and necessary...

The credit checks centre around credit risk to APT and necessary provisioning and is not necessarily going to assist on AML compliance as the purpose of laundering is to wash the money and get it into a legitimate flow or ending asset.

AUSTRAC deals with Money laundering and terrorism financing. Their notice states there has been reasonable grounds to suspect they are in breach and I suspect this is due to fact APT rely on with Small transactions and use that as a reason to not report anything. They are below any 10k threshold. This would seem reasonable to me
and no regulator is going to be concerned with one off 1.5k transactions.

What APT will need to show is they have monitoring controls to identify and report instances deemed to be ‘suspicious’. In order to do that they need to define parameters that make a ‘suspicious’ occurrence
Knowiing the transactions are small it really comes down to identifying customers who:

-could have more than one account - ensuring that you can’t

-customer who has multiple transaction (every day) and patspays immediately so can start again next day. In this instance they are not using the pAy later benefit and this would be deemed suspicious as it’s actually a hassle for the customer. The bank if there’s transaction to pay apt may have some controls though it’s less than 10k there may be a flag if their customer is paying apt every day to clear a daily bill. Still apt should have their own controls.

i don’t think this is too onerous to implement and hopefully they are already doing this. Whether they would have been in 2015 I’m less confident about but AUSTRAC want to snap this in the bud and make sure they have controls in place or get them in now. They’re not actually the bad guys and start ups can grow faster in some areas than others so I overall it’s a good thing to occasionally give a stern talking to ensure we all lift our game.

note it’s not up to apt to make a call on whether transactions is actually dodgy or not they just need to put a control in place to define a suspicious reportable event and then report to austrac and let them do what they want with it. (put it on a list and do nothing unless same name comes up) keeps austrac confident they have compliance controls in place.

overall I would not expect a long term issue. It’s possible they get a slap on wrist if they say they adopted new controls at such a date and weren’t doing too much in 2015 but the important thi g is that they are / get in compliance now