We are required to conduct ongoing due diligence in relation to the services we provide.
This means we must keep client information current and may ask you to confirm or update your details from time to time.
Where something unusual comes to our attention during the course of providing services, we may be required to assess the circumstances.
Our ongoing monitoring processes may include:
- identifying suspicious transactions or behaviour that could require further investigation;
- screening clients and connected individuals against the DFAT Consolidated List;
- monitoring politically exposed person information;
- carrying out adverse media searches where appropriate;
- reviewing and reverifying information where its accuracy is uncertain or a client’s risk changes;
- monitoring significant changes in the nature or purpose of the business relationship;
- reviewing transaction information for physical cash transactions of $10,000 or more;
- lodging threshold transaction reports where required;
- lodging suspicious matter reports where the required level of suspicion exists;
- completing Extrado’s annual AUSTRAC compliance reporting; and
- arranging for Extrado’s AML/CTF program to be independently evaluated.
These processes form part of our legal obligations and do not mean that we have personal concerns about a particular client.
