InsightCFS                     Anti-Money Laundering and Counter-Terrorism Compliance Policy                                                

 

This Policy is reviewed and updated each two months until October 2024 when it will be reviewed and updated each 6 months or in line with legislation changes.

Updated   16 Jan 2025

Next review 16 June 2025

 

The policy applies to InsightCFS and My Charity Raffle and which are businesses of Insight Holdings Consolidated Pty Ltd (ACN 111 803 475) See contact details below.

In compliance with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Act),  Insight has adopted this policy to manage the identification of clients and transactions which may require reporting to AUSTRAC.

Insight provides payment management and money transfer services to charity organisations as part of our work of providing raffle promotion or raffle management services.

Insight’s raffle fundraising activities are conducted on behalf of charitable and not for profit organisations which are an identified area for risk of money laundering activities. It is possible that Insight will be approached by people who may wish to use Insight’s services in breach of the Act. It is still to be determined that Insight provides a designated service and therefore may be a reporting entity.

See AML and CTF Act 2006 section 6 See Table A Items 30, 31 and Table B.

For the purposes of the Policy, money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the unlawful proceeds appear to have been derived from legitimate origins or constitute legitimate assets.

Background

Insight does not receive or control large individual sums from the public (transaction are normally under $50 and generally always below $1,000) and funds are both received by Insight and passed directly to clients via the banking processes. All clients of the InsightCFS business (Insight Holdings Consolidated Pty Ltd) can be easily identified by government registers including ASIC, under which they are likely to supervised or assessed for similar risks.

In this policy the following expressions are used:

AML Act means the Anti-Money Laundering and Counter-Terrorism Financing Act 2006

We, or Our, or Us refers to Insight Holdings Consolidated Pty Ltd and the businesses and companies in the Insight group of companies.

Organisations refers to charities, not for profit or other organisations which apply to use Insight’s services.

Clients refers to charities or not for profit organisations which contract to use our services.

Customers means raffle ticket buyers and potential customers.

Destination Bank account is the account to which sales receipts are directed.

Services refers to the conduct of Raffles and the activities which are contracted to be provided which may include payment services.

Scope

This policy applies to all Insight group businesses and related companies engaged in conducting and marketing raffles for clients in Australia. The Compliance Officer is responsible for ensuring that reports of suspicious transactions are generated.

Staff or teams engaged in this work include:

Sales – sales staff and their supervisors directly engaged in accepting purchase orders.

IT and Banking – reports which identify patterns or large sums.

Marketing and Administration – awareness of potential clients whose activities may suspect that money laundering is a motivation and that further enquiry is required.

This policy applies exclusively to operations within Australia.

Purpose

The purpose of the act and therefore this policy is to ensure that raffle entry sales are not used for money laundering funds, that funds are not used to support terrorism and that funds are used for the purpose represented to the customers who purchase entries.

Policy

It is Insight policy to operate our services and conduct financial transactions in a way which will prevent the use of Insight’s payment processing services for money laundering. Specific areas of the business are responsible for vetting organisations which apply to use Insight’s services, assessing transactions and testing transactions for potential money laundering activities.

Each team or business unit and location shall implement and apply risk-based procedures reasonably expected to prevent, detect and cause the reporting of transactions.

Practice

These requirements apply in addition to raffle permit and related registration requirements.

A             Training

All customer facing staff at Insight are trained in Responsible Gaming detection including suspicious transactions.

All staff will receive an annual update to raise awareness of the Act  and the issues it addresses as an obligation of the business, what signs should remind them to seek assistance and the operation of relevant reports.

Training is to occur each year and each new staff member in the area will receive introductory training. Staff engaged in induction of new clients or handling large sums will receive specific training on the processes which are designed to comply with the AML Act.

B             Customer Identification Program

We identify the entity and directors and CEO of all new clients and any changes by reference to independent, Government sources. Directors or their delegates are responsible for receipting and sending funds and are responsible for audit and reconciliation of funds received from or processed by Insight.

We identify the beneficiaries of funds received and the beneficial owners of an organisation. Insight will enquire so as to understand that the application of funds delivered from the raffle activities is consistent with the marketing of the entries to the public and the approved objects of the organisation.

Insight only conducts raffle sales for Australian entities.

To identify Australian companies the following forms of identification may be sufficient:

  • a public document issued by the company (such as an annual report)
  • searching a relevant government database Australian Securities and Investments Commission (ASIC) and ACNC.
  • searching the licence or other records of the relevant regulator.

Identification of Personnel

We identify directors by reference to photo ID, addresses and company or other entity searches and these individuals must be in control of  the  Destination bank accounts.

All new clients must pass AML checks before transactions can commence.

Customer ID updating

Changes to the organisation and its activities are to be identified as part of regular processes for the client including:

  • Updating searches
  • Data matching for changes in customer details
  • Requests for updated details.
  • Requirement for notification of changes to activities or key personnel.

 

C             Client Transactions are checked:

Raffle entry buyers are not identified individually beyond contact information necessary for further contact and to minimise the risk of purchases by children.

Insight will identify unusual patterns of purchases by customers. Unusual patterns will include consistent high value purchases from individuals or groups.

Usual Insight payment checking processes also include:

  • New purchase payments under 100 are delayed 10 days.
  • New sales staff do not conduct instant transactions over 500.
  • Transactions over $400 are reviewed and checked for completeness.
  • Transactions over $2,000 are checked for completeness and if unusual the customer will be called to confirm the transaction.
  • Repeat high value sales (more than 3 over $500 in 6 months) are identified and reported to the AML Compliance Manager.

Entries can be sold to non-residents but all prizes must be received in Australia.

Prizes are delivered to the prize winner. Prizes are not substituted for cash. Prize winners must receive the prize in Australia.

 

 

Draft Collection Documents.

New Client

REQUIRED CUSTOMER INFORMATION

  • Entity Name
  • Trading names
  • Address
  • ACN ABN ACNC registration numbers
  • Copy of Articles including objects
  • Latest Bank Statement

The following information will be collected for all new raffle accounts:

  • Director Names,
  • Date of birth,
  • Address,
  • Identification number, Drivers licence, Director number,
  • Photo identification (driver’s licence or other comparable photo source).

 

Client verification information may be collected via the internet and processed in network systems but once processed (including identification of the course document), all original sources will be deleted.

Wherever possible Insight will rely on external electronic services to support enquiries.

VERIFYING INFORMATION

Based on the risk, and to the extent reasonable and practicable, Insight will ensure that it has a reasonable belief of the true identity of its customers. In verifying customer identity, appointed producers shall review photo identification.

Insight shall not attempt to determine whether the document that the customer has provided for identification has been validly issued. For verification purposes, Insight shall rely on a government-issued identification to establish a customer’s identity. Insight, however, will analyse the information provided to determine if there are any logical inconsistencies in the information obtained.

Insight will document its verification, including all identifying information provided by the customer, the methods used and results of the verification, including but not limited to sign-off by the appointed new client administrator as to matching  and photo identification.

Client verification information may be collected via the internet and processed in network systems but once processed (including identification of the course document), all original sources will be deleted.

 

Insight Holdings Consolidated Pty Ltd  ACN 111 803 475

Level 5, Suite 5.02 241 Commonwealth Street, Surry Hills NSW 2010

PO Box 968, Strawberry Hills NSW 2012

Phone 1300 855 226

info@insightcfs.com.au

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