The Association of Superannuation Funds of Australia (ASFA) has told the Federal Government that its proposed approach to anti-money laundering and counter terrorist financing legislation is inappropriately prescriptive.
In a submission filed with the Attorney General’s Department, ASFA highlights the highly prescriptive nature of the draft legislation and notes that subsequent amendments to the draft have so far failed to address these concerns.
ASFA is arguing that reporting entities should be able to introduce their own policies and procedures in line with high-level principles put in place by the Government.
It said a genuinely risk-based approach would allow for features of the entity, product and customer to be factored into the development and implementation of an anti-money laundering and counter terrorist financing program.
“ASFA’s strongly held view is that any anti-money laundering and counter terrorist financing regime in Australia must recognise the unique features of the Australian superannuation system, including employer compulsion to pay superannuation on behalf of employees, preservation of superannuation until retirement, and the regulatory and reporting requirements on superannuation funds,” it said.
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