It is not uncommon for company senior executives to shake their heads at the mention of the word ‘fraud’. “No, we don’t have that problem.” “Our people wouldn’t do that.” “Surely the procedures will take care of that” are among the typical responses.

2014 is an eventful year when it comes to compliance. This article outlines the most significant regulatory events and updates of 2014 from the perspective of CFDs and FX providers. It should be noted that these events are relevant to a lot of other Australian Financial Services Licensees and Reporting Entities (REs) under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act).

Fraud cases flood the media these days and financial losses suffered by the victims can easily range anywhere between a few dollars and hundreds of thousands of dollars. The figures are much bigger for businesses. We become increasingly vulnerable to fraud due to the advances in technology and the easy access to personal information.

In comparison, however, a reporting entity’s ongoing Anti-Money Laundering and Counter-Terrorism Financing (‘AML/CTF’) obligations do not appear to have received sufficient attention. This article aims to shed some light on one of the ongoing obligations – the transaction monitoring program, which is often under-implemented and misunderstood.