Anti-Money Laundering and Counter-Terrorism Financing


Grant Holley

The Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth) (AML/CTF Act) regulates entities which provide one or more ‘designated services,’ as listed in s6 of the AML/CTF Act.  One of the designated services in s6 refers to issuing or selling an interest in a managed investment scheme.


There are limited circumstances in which a Fund Manager is exempt from complying with customer due diligence requirements.  For example 21.3(1)(a) of the Anti-Money Laundering and Counter Terrorism Financing Rules grants a general exemption by s247 of the AML/CTF Act if an entity is selling shares in a fund on the ASX.


However, more detail would be required to determine if a specific Managed Fund would be exempted from AML/CTF obligations, and we would be happy to provide tailored legal advice regarding your product.


Author: Grant Holley (Partner)

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