This submission is in response to AUSTRAC’s and the Attorney-General’s Department’s Issues Paper Review of the AML/CTF Regime. Australian regulators (including the RBA, APRA and AUSTRAC) have an interest in raising the profile of the remittance industry and recognising the important role it plays for Australia and its relationship with the Pacific Islands and Asia. The Review of the AML/CTF regime would be strengthened and improved by taking into consideration the suggestions in this submission.

This submission is supported by the Centre for International Finance and Regulation (CIFR) (project no. E226), the United Nations Capital Development Fund (UNCDF), Standard Chartered Bank and the University of New South Wales (UNSW). CIFR is a Centre of Excellence for research and education in the financial sector which is funded by the Commonwealth and NSW Governments and supported by other consortium members (see <www.cifr.edu.au>). All responsibility lies with the authors.