This Bill outlines updates to address verification requirements, extends deadlines for reporting transactions and suspicious activity, and clarifies definitions regarding cheque deposits. These changes aim to streamline compliance processes and reduce the burden on reporting entities while maintaining the integrity of the regulatory framework.

Who should pay attention?

All reporting entities need to take note of this Bill. While some changes will specifically impact certain types of entities, others will affect everyone involved in compliance.

What’s changing?

The Bill proposes four key changes that will impact how reporting entities manage their compliance efforts:

1. Address verification: The new proposal allows reporting entities to adjust the steps taken for address verification based on the level of risk associated with the transaction. This means that instead of a one-size-fits-all approach, entities can tailor their verification processes to the risk level, though they must still establish a connection between the address and the customer.
2. Extended reporting times: The time allowed for reporting prescribed transactions will increase from 10 to 20 working days. This change aims to provide more flexibility and ease the compliance burden.
3. Lawyer reporting times: For law firms, the time to submit suspicious activity reports will extend from three to five working days, allowing additional time to navigate client confidentiality issues.
4. Cheque exclusions: The definition of an “occasional transaction” will now only exclude cheque deposits made at registered banks or non-bank deposit takers, clarifying previous ambiguities.

Next steps

The Bill is currently in the early stages of parliamentary discussion, and it’s uncertain when it will progress further. Reporting entities are encouraged to consider submitting feedback during the Select Committee stage, particularly regarding the address verification proposal, which they may wish to see aligned with the previously proposed changes.

If you have questions about the Bill or the AML/CFT reforms, please reach out to our team for guidance.