The commencement order established that the Act would come fully into force on the 30th June 2013. Reporting entities have until this date to plan and implement their systems and controls to become compliant. Once in place you will need:
- A written risk assessment of the money laundering and financing of terrorism that you could expect in the course of running your business;
- Initiate and run an AML/CFT program that includes procedures to detect, deter, manage and mitigate money laundering and the financing of terrorism;
- Vet your senior managers and AML staff;
- Train your senior managers and AML staff; and
- Appoint an AML/CFT Compliance Officer.