Some superannuation trustees are likely to question the costs associated with accessing the Document Verification Service (DVS) within the Attorney General's Department because of the relatively low frequency with which they would access the service for Anti-Money Laundering/Counter-Terrorism Financing (AML/CTF) purposes.
That is the assessment of the Association of Superannuation Funds of Australia (ASFA) which has responded to a guidance note issued by AUSTRAC by supporting the general direction of guidance note in assisting reporting entities to understand how the DVS can be used to identify and verify individual customers.
While acknowledging the value of the DVS as a single source document verifying service and not an identity verifying service, the ASFA submission said that it would be of "limited use in the majority of the day-to-day low-risk Know Your Client (KYC) actions that trustees of superannuation funds undertake".
"However, a service like the DVS would likely be useful, in the superannuation context, where there is uncertainty as to the validity of the verifying document (eg the trustee thinks the passport supplied is a fake), or the member if in a high-risk category and the trustee extends its KYC activities to include verifying the underlying identity document itself," the submission said.
It said that it believed the frequency with which a superannuation trustee would need to verify the validity of an underlying document under its AML/CTF program is relatively low, given the generally low risk nature of superannuation.
"Therefore, when weighed against the cost of establishing access to the DVS, ASFA believes that many superannuation trustees will question whether DVS is a cost effective option for their fund," the ASFA submission said.
