Australian Financial Services Licensing (AFSL) Forum

#4716 Reply

Hi Lidis,

 

Thanks for the question.

 

The fund’s obligations will depend on whether you are a reporting entity, and thus required to comply with the AML/CTF legislation. Additionally, you should be aware that refunding money to third parties represents an increase in ML/TF risk.

 

In short, this is a complex legal question and a range of laws apply. We would recommend that you seek professional legal advice. Please feel free to contact our financial services team.

 

 

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