Anti-Money Laundering and Counter-Terrorism Financing Policy

Purpose. This policy sets out the firm's program for identifying clients, assessing money laundering and terrorism financing risk, monitoring transactions and reporting to AUSTRAC as required by the Anti-Money Laundering and Counter-Terrorism Financing Act 2006.

1.Purpose and scope

Ledger and Lane provides designated services through its broking and financial services activities and is a reporting entity. This policy applies to every staff member and representative and to every client, including clients who only use bookkeeping and tax services, because the firm applies one client identification standard across the business.

2.Customer identification

Every client must be identified and verified before a designated service is provided, using the Client Onboarding and Identification Form. Individuals will be verified against a current photo identity document and a second document. Companies, trusts and partnerships will be verified against the register or deed, and every beneficial owner holding 25 per cent or more must be identified. Records of verification must be kept for seven years after the relationship ends.

• Individual: photo identity document plus a second document
• Company: company register extract and directors
• Trust: trust deed, trustee and beneficiaries
• Beneficial owners of 25 per cent or more identified
• Politically exposed persons identified and approved by the Compliance Manager

3.Risk assessment

Each client is assigned a risk rating of low, medium or high at onboarding based on client type, the services used, source of funds, country connections and delivery channel. High risk clients require enhanced due diligence, approval by the Compliance Manager and annual review. The firm's overall risk assessment will be reviewed annually.

4.Ongoing due diligence and monitoring

Staff must monitor client activity for transactions or requests that are inconsistent with what they know about the client, including unexplained large deposits, third-party funds, structured payments, reluctance to provide documents and requests to move funds through the firm's trust account. Client information must be reviewed and updated at least every three years for low risk clients and annually for high risk clients.

5.Reporting

A staff member who forms a suspicion must report it to the Compliance Manager the same day using the internal suspicious matter form. The Compliance Manager will decide whether a suspicious matter report must be lodged with AUSTRAC within the statutory timeframe. Staff must never tell the client that a suspicion has been formed or a report made. Threshold transaction reports will be lodged for cash transactions of 10,000 dollars or more.

6.Training and records

All staff must complete anti-money laundering training at induction and annually. The Compliance Manager will keep records of training, risk assessments, verification and reports and will arrange an independent review of the program every two years.