Extract from the report:
Introduction
APF welcomes the opportunity to provide input to this review of the AML/CTF regime. APF has been kept informed of the operation of the regime through its representative on the AUSTRAC Privacy Consultative Committee – initially Mr Chris Connolly and since 2000 Mr Nigel Waters. APF has worked closely with the two other consumer members of the PCC– Ms Jan Whitaker (who is also an APF member) and Ms Georgia King-Siem from the Liberty Victoria (previously Mr Michael Pearce).
We would like to acknowledge the continuous commitment of successive AUSTRAC CEOs and senior staff to consultation with civil society NGOs through its PCC, since it was established in 1994. The amount of information provided, frankness of discussion, and comprehensive record keeping in the form of minutes is unprecedented for any government agency, and provides a model that should be followed APF submission on AML-CTF Review 2014 by others. Through the AUSTRAC PCC, the relevant section of the Attorney-General’s Department has also been relatively open and consultative about successive amendments to the legislation.
Our relative satisfaction with the level of consultation does not translate into comfort with the AML-CTF regime itself. APF has from the outset opposed the highly privacy intrusive nature of the AML-CTF (formerly FTRA) record-keeping and reporting regime as wholly disproportionate to the declared objectives.
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