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Anti-Money Laundering and Counter-Terrorism Financing Compliance Statement

1. Administrative Information

2. Senior Management - Names and Backgrounds
Please refer to the list below for details on the Board of Directors and the Senior Executives of the Cuscal

  • The Board of Directors
  • The Executive Committee
    • Craig Kennedy - CEO
    • Iain Keddie - CFO and General Manager, Corporate Services
    • Adrian Lovney - General Manager, Business Development, Strategy and People
    • David Heine - General Manager, Product and Operations
    • Omaya Robinson - Head of Transactional Products
    • Angela Donohoe - CIO and General Manager, Business Technology and Project Services

3. Anti-Money Laundering and Counter-Terrorism Financing Measures in Cuscal
Cuscal is subject to, and complies with, Australian law. Australian laws applicable to Cuscal:

  • Financial Transaction Reports Act 1988 and associated regulations
  • Proceeds of Crime Act 2002 and associated regulations
  • Criminal Code Act 1995 and associated regulations

The principal piece of legislation is the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act). Under the AML/CTF Act. AUSTRAC, the regulatory authority charged with oversight of the legislation, has made Rules relating to AML/CTF obligations. Cuscal has implemented the requirements of this Act within the specified timeframes. The legislation has a staggered implementation timeframe with full implementation required by 12 December 2008. Cuscal has adopted internal policies, procedures and controls to ensure that it complies with existing legislation.

  1. Customer due diligence / Know Your Customer:
    Cuscal has policies and procedures in place to comply with the obligation to identify customers as required by the Financial Transactions Reports Act 1988 ('FTRA'). The recently enacted AML/CTF Act 2006 requires enhanced Customer Due Diligence for new customers and certain existing customers. Additional controls and assurance processes have been implemented to comply with the Act.

  2. Record retention:
    Records relating to customer identification are maintained and kept for seven (7) years in Australia after the termination of services offered by Cuscal.

  3. Monitoring of suspicious activities or transactions:
    Monitoring is carried out through a risk-based approach. Cuscal staff receive periodic training and reminders of the requirements to report suspicious transactions and how to identify them.

  4. Reports of suspicious transactions:
    Cuscal is required to report any suspicious customer activities or transactions to the regulatory authority, AUSTRAC. Internal policies and procedures are in place to ensure compliance with the applicable legislation and regulatory requirements.

  5. Reports of significant account and non-account based cash transactions:
    Cuscal is required to report these activities to the regulatory authority, AUSTRAC. Internal policies and procedures are in place to ensure compliance with the applicable legislation and regulatory requirements.

  6. Employee training program:
    Training is provided to business units that offer products and services that are subject to the legislative requirements. Cuscal staff impacted by the Act receive periodic training and reminders on the detection and reporting process for suspicious activities, new customer identification procedures, and record keeping. Communication of changes to AML/CTF legislation or any emerging risks are communicated to the relevant staff.

  7. Agents of Cuscal:
    Agents of Cuscal are required to carry out their duties in accordance with agreements entered into with them and includes, where applicable, any customer identification and know your customer requirements. In complying with the recently enacted AML/CTF Act 2006, additional controls and assurance processes have been implemented to manage this ML/TF risk.

  8. Independent audit and compliance review function:
    Cuscal's auditors and internal audit conduct audits and compliance testing of all Cuscal's policies and operational procedures including those applicable to AML. The audit and compliance programs are approved by senior management.

  9. Correspondent banks:
    Cuscal does not have any Correspondent Banking relationships.

  10. Shell banks:
    Cuscal does not conduct business with shell banks.

  11. PEPs:
    A risk based approach considers PEPs as a ML/TF risk.

  12. AML Officer:
    The contact for AML related matters has been provided above. In complying with the recently enacted AML/CTF Act 2006, Cuscal has designated a person as the 'AML/CTF Compliance Officer' at the appropriate management level.