Westpac's page on the subject is
here.
Westpac
Personal BankingBusiness BankingCorporate BankingWestpac Info
Site index | Contact us | Locate us
Site Search
Back to: Anti Money Laundering
Anti-Money Laundering and Counter-Terrorism Financing - Westpac Group Policy
* Introduction
* Scope
* Definitions
* Principles
* Key roles and responsibilities for using this policy framework
Introduction
Intent
The Westpac Group aims to prevent, detect and not knowingly facilitate money laundering and terrorism financing. Westpac does this to protect the Group's reputation, to comply with relevant laws and to be a good corporate citizen. This policy forms part of our overall Environmental, Social and Governance approach. Westpac also aims to comply with anti-money laundering (AML) and counter-terrorism financing (CTF) law in a way that complements business priorities.
The purpose of this policy is to:
* Make employees, contractors and third parties aware of the meaning of AML and CTF
* State the Group's attitude towards money laundering and the financing of terrorism
* Outline the key roles and responsibilities of the Group's employees, contractors, third parties and business units in relation to AML/CTF
* Document requirements of Anti-Money Laundering and Counter-Terrorism Financing Act 2006, which replaces over time the requirements of the Financial Transactions Reports Act.
Risk of facilitating Money Laundering or Terrorist Financing
Westpac faces significant risk if it (or its employees) knowingly facilitate or fail to put in place the appropriate training, processes and systems to prevent the facilitation of money laundering or terrorist financing.
Back to top
Scope
This policy applies to all Westpac Group employees, secondees, contractors and people on work experience in Australia, New Zealand, the Pacific and other overseas offices (called "employees and contractors" in this policy).
Back to top
Definitions
Money Laundering
Money laundering is the process by which criminals use the financial system to hide the proceeds of crime, turning "dirty" money into "clean" laundered money. Criminals undertake money laundering in order to reduce the risk of detection and confiscation by the authorities.
Money laundering is just as serious as the underlying crimes that generate the money that is laundered. For example, criminals are less likely to engage in drug trafficking if they are unable to profit from it financially in a way that avoids detection. Preventing money laundering, therefore, can help prevent drug trafficking.
Terrorism Financing
Terrorism financing differs from money laundering in two ways:
* Very small sums of money can do very large amounts of damage in the hands of a terrorist. For example a bomb that costs a few thousand dollars to make can kill and cause billions of dollars damage.
* Although terrorists may finance their activities through crime, particularly fraud involving stolen cheques or fake or stolen credit cards, legitimate funds can also be misappropriated for terrorist financing.
These attributes of terrorism financing show the importance of reporting all suspicious activity, even if the sum of money involved is relatively small.
Suspicion
Having a 'suspicion' means that we suspect that a customer is using or seeking to use our financial products or services (referred to as "designated services" in the Australian AML/CTF legislation) to launder money or finance terrorism and one of the following conditions is met:
* We suspect on reasonable grounds that the customer is not the person they claim to be
* We suspect on reasonable grounds that an agent of the customer is not who they claim to be
* We suspect on reasonable grounds that information Westpac has concerning the provision or prospective provision, of a designated service
o May be relevant to investigation of, or prosecution of a person for evasion, or an attempted evasion, of a taxation law
o May be relevant to investigation of, or prosecution of a person for evasion, or an attempted evasion, of a law of a State or Territory that deals with taxation law
o May be relevant to investigation of, or prosecution of a person for, an offence against a law or the Commonwealth, or of a State or Territory
o May be of assistance in the enforcement of the Proceeds of Crime Act 2002 or regulations under that Act
o May be of assistance in the enforcement of a law of a State or Territory that corresponds to the Proceeds of Crime Act 2002, or regulations under that Act
* We suspect on reasonable grounds that the provision, or prospective provision, of the service is preparatory to the commission of an offence connected to financing of terrorism
* We suspect on reasonable grounds that information Westpac has concerning the provision, or prospective provision, of the service may be relevant to the investigation of, or prosecution of a person for an offence connected to financing of terrorism
* We suspect on reasonable grounds that the provision, or prospective provision, of the service is preparatory to the commission of an offence connected to money laundering
* We suspect on reasonable grounds that information Westpac has concerning the provision, or prospective provision, of the service may be relevant to the investigation of, or prosecution of a person for an offence connected to money laundering.
Back to top
Principles
The principles governing the Group's approach to money laundering and terrorism financing are:
We will maintain an AML/CTF program as required by the AML/CTF Act. This means we will:
* Have and comply with an AML/CTF program
* Implement processes designed to identify, mitigate and manage the risk we may reasonably have that the provision of designated services by us, might (whether inadvertently or otherwise) involve or facilitate money laundering or financing of terrorism
* Implement applicable customer identification procedures for our customers.
We comply with the law and aim for best practice:
* We comply with national AML/CTF laws in the countries in which we operate, and have regard to international best practice as detailed, for example in the recommendations of the Financial Action Task Force (FATF)
* We work in conjunction with the Australian Government, and the governments of any country in which we operate, and support these governments' objectives in relation to prevention, detection and control of financial crime.
* We will refuse to enter into relationships with shell banks.
We take a risk-based approach:
* We train our employees and contractors to be alert to money laundering and terrorism financing risks
* Our systems, procedures and training are developed to take account of the differences in AML/CTF risk in the countries in which we operate
* Due diligence processes for customers are tailored according to our analysis of the AML or CTF risk associated with those customers (or customer groupings) and the designated services, geographies or channels involved
* We check relevant transactions, including by referring to world-wide terrorist lists, in accordance with the Suppression of Financing of Terrorism legislation
* We conduct research into money laundering and terrorism financing risks. The output of this research is used for internal training and monitoring customer activity
* We assess the risks of our products, and monitor the activity of our customers using a risk-based approach.
We adopt a centralised model (where appropriate):
* For AML/CTF purposes Westpac will operate as a Group and will establish a Designated Business Group (as permitted by the AML/CTF legislation) to adopt standard processes where appropriate
* For AML/CTF purposes Westpac will adopt consistent tools for performing all risk-based assessment (i.e. a single Risk Assessment Model will be used by all business units to segment customers into ML/TF risk categories).
We identify customers in accordance with the current legislative requirements in the countries in which we operate.
We act on our suspicions:
* We report any suspicious matters or activity to the appropriate authorities in a timely and comprehensive manner, as required by local laws or our own policy, which ever provides the greater standard.
* We will refuse to enter into business relationships where we suspect that the Group's products or services might be used for illegitimate purposes. We will not provide the reason to the customer to avoid tipping off the customer.
We maintain a high standard of record keeping to assist in the investigation of money laundering and terrorism financing. For example, when responding to an official police request, providing clear and complete copies of records could help locate a suspect and prevent a terrorist attack.
Back to top
Roles and responsibilities for using this policy
Westpac Banking Corporation Board of Directors (the Board) and Westpac Senior Management have ongoing oversight of our AML/CTF policy and procedures.
Employees and contractors must comply with the AML/CTF policy and procedures, report suspicious matters or behaviours and attend training as required for their role.
We have also appointed an AML Officer (referred to at Westpac as Money Laundering Reporting Officer - MRLO). The MLRO is the nominated person who will support and coordinate senior management focus on managing the money-laundering / terrorist financing risk in individual business areas. The MLRO will also help ensure that Westpac's wider responsibility for forestalling and preventing money laundering / terrorism financing is addressed centrally, allowing an enterprise-wide view to be taken of the need for monitoring and accountability.
We have also established a Group AML Unit that provides advice and specialist support to Compliance, business units and the MLRO to enable them to fulfil their responsibilities in the policy framework.
