Simplicity + Certainty = Confidence
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Secure

Secure

Your information is securely held, communications are safely encrypted. Our fully encrypted backups occur often and regularly. Flexible and secure user password security.

Fast

Fast

Fast interfaces, user experience and reporting through the latest database design and web technology. User management tools aide efficient processes

Simple

Simple

Uncluttered user interfaces, multiple browser tab access, effortless data links. Our user-friendly and easy to learn user interface means no steep learning curve. Logical data entry flow with what you expect where you expect.

Customisable

Customisable

You select the modules you use and customise to your needs. You control your reports' content, you tailor your installation to suit your businesses needs

Standardised

Standardised

We support the global standards on Risk Management (ISO 31000) and Compliance (ISO 19600) and APRA SSP 220

Centralised

Centralised

One stop for all of your risk and compliance office needs. View completed and incomplete controls. Retain all your controls and records in the one accessable data base

How it Works

Feature diagram

CRS Certus becomes your record of your risks, risk profile, risk mitigators, obligations, responsible managers and staff, policies and procedures. It holds your proof of control execution. It facilitates recording and managing issues, incidents and complaints. CRS Certus can be interrogated to deliver reports on all data it holds in a format your audience needs.

Risks

Full risk management system. Customisable risk register. Multiple entity ratings support. Links to mitigating controls and issues register. Risk appetites tied to strategic objectives. Risk tolerance triggers and questionnaire system.

Obligations

Record obligations. Link to legislative or regulatory sources. Reconcile obligations with business controls

Controls

Document business controls. Link to risks and obligations. Assign responsibilities to managers. Automatically generate controls self-assessment questionnaires. Managers alerted when questionnaires are ready, complete within CRS Certus

Assessments

Controls response assessment navigation. Record testing results. Full audit records of resolution and further action. Directly load adverse responses into Issues Register.

Incidents

Capture incidents originating from within CRS Certus and reported by your business. Customise incident categories. Workflow management. Assign activities. Capture reportability assessment, related documents and developments.

Complaints

Customise complaint categories. Seamless flag as incidents, breaches or risk mitigation controls failures.

Registers

Breach register with regulator reporting assessments. Personal dealing approvals and register, gifts & benefits, training, conflicts of interest, relatedy party, legal documents, administrative documents, publications, office holder registers amongst others.

Alerts

Email alerts issued out of the system directed to your defined positions. Customisable email content and triggers. Email service log validates that communications are sent.

Policies & Procedures

Policies and procedures library. Alert users to new content to review within CRS Certus. Capture user confirms of access and understanding of policies and procedures. The library becomes your single point of truth.

Reporting

Flexible reporting to PDF and XLS(X). Customisable report content, period and presentation, tailored and relevant for the audience. Reports returned immediately. Aides regulatory enquiry, annual audit, demonstrates the control you have over your business

Consultancy and Outsourced Management

In addition to providing CRS-Certus as a software service, we provide consulting and outsourced management services. These services are available separately from CRS-Certus.

We can help to:

  • Operationalise your risk and compliance management system.
  • Workshop your risks.
  • Build Controls.
  • Document your regulatory obligations.
  • Implement incident/complaints reporting.
  • Document your policies & Procedures

Compliance & Risk Services Pty Ltd has been providing risk and compliance management solutions for businesses for over 10 years.

Our speciality in financial expertise

We have particular experience with financial Australian financial institutions such as Australian Financial Services Licensee, APRA regulated entities, Australian Credit licensees and AUSTRAC reporting entities.

  • Australian Financial Services ('AFS') Licence applications and licence variations
  • RSE licence applications
  • AFS Licence compliance reviews
  • Managed investment scheme registrations
  • Draft compliance plans
  • Draft Product Disclosure Statements ('PDS')
  • PDS due diligence
  • MDA contracts
  • Provide outsourced compliance management
  • Anti-money laundering & counter terrorism financing ('AML/CTF') programs
  • Independent reviews of AML/CTF programs
  • External Compliance Committee members
  • Temporary compliance staff placements
  • Risk management frameworks
  • Local agent for foreign licensees
  • Technical and product advisory services
  • Responsible manager training

Our values and ideals

Experience

We are experienced risk and compliance management practitioners experienced in developing and operating risk and compliance management systems.
CRS-Certus is developed through our experience as risk and compliance management practitioners.

In-house programming team

Our programming team is retained in-house. We believe that the partnership of practitioner and programmer provides a strength that few competitors may match.

Secure IT architecture and backups

Our system uses contemporary database design, programming languages, and hardware. We have implemented a constant backup regime using offsite encrypted storage.

Trust

We have provided services to over 200 clients over the globe. We have acted as topic experts under ASIC enforceable undertakings, engaged as experts in litigation and ASX disciplinary reviews.

Articles

Changes to AML/CTF Requirements
By Sharman Grant at 28/09/2021
ASIC guidance on breach reporting
By Gerald O'Byrne at 17/09/2021
ASIC v RI Advice Group Pty Ltd – failure to properly supervise an Authorised Representative
By Terry Dalziel at 12/08/2021
ASIC reference checking and information sharing protocol
By Gerald O'Byrne at 26/07/2021
ASIC email to licensees - reportable situations
By Murray Jones at 25/06/2021
Structural change in Stock Broking
By Adam Bold at 23/06/2021
Ongoing Fee Arrangements - Obligations and Client Consent
By Terry Dalziel at 16/06/2021
Property related AFS Licensees and APRA Connect
By Gerald O'Byrne at 09/06/2021
Change in treatment of leases for calculation of net asset, adjusted surplus liquid funds and surplus liquid funds – no longer an excluded asset
By Terry Dalziel at 02/05/2021
New Compliance Standard replaces ISO 19600
By Murray Jones at 20/04/2021
Consent to Deductions – Ongoing fee arrangements, information to be provided where a fee is to be deducted from a clients account: An updated.
By Terry Dalziel at 30/03/2021
Special Purpose Financial Statements ceasing from 1 July 2021
By Terry Dalziel at 30/03/2021
Disclosure of lack of independence – further disclosure via legislative instrument
By Terry Dalziel at 25/03/2021
Financial Sector Reform (Hayne Royal Commission Response No. 2) Bill 2020 now Law
By Terry Dalziel at 11/03/2021
Claims handling and settlement service and the need to be authorised
By Terry Dalziel at 01/03/2021
Wholesale and Sophisticated Clients can access AFCA
By Adam Bold at 22/01/2021
Financial Sector Reform (Hayne Royal Commission Response No. 2) Act 2020 - Impact on financial advisers
By Terry Dalziel at 16/12/2020
ASIC commences action against the RI Advice Group Pty Ltd
By Terry Dalziel at 24/08/2020
Deferral of mortgage broker reforms and design & distribution obligations
By Murray Jones at 12/05/2020
ASIC amends requirements where COVID-19 related advice is provided
By Terry Dalziel at 16/04/2020
Changes to AML/CTF Requirements

Changes to AML/CTF Requirements

On 17 December 2020, the Cth passed the Anti-Money Laundering and Counter-Terrorism Financing and Other Legislation Amendment Bill 2020 (the Amendment). The AML/CTF regime modifications introduced changes to: 

  • customer identification procedures; 
  • banking relationships; 
  • tipping-off offences; 
  • access to information, and 
  • cross-border movements of money.

The changes come into force on 18 June 2021.

Changes to customer identification
New sections 37A and 37B of the AML/CTF Act (the Act) allow reliance on customer identification procedures carried out by a third party if:

  • an agreement ensures the third party is subject to supervision;
  • there are regular assessments of the agreement; and
  • there are reasonable grounds to believe that the agreement in practice meets the KYC requirements of the AML/CTF Rules.

Where these are met, the reporting entity has a safe harbour from liability for isolated failures by the third party.

Further, section 38 of the Act now allows reliance on KYC procedures carried out by another reporting entity or foreign entity if:

  • the other party has undertaken the KYC procedures prescribed by the AML/CTF Rules; and
  • there are reasonable grounds for reliance having regard to the money laundering and terrorism risks.

Unlike the new sections 37A and 37B, there is no safe harbour from liability but the amended section 38 allows reliance on KYC completed by other trustworthy parties.

The prohibition in section 32 of the Act that prevents a reporting entity from providing designated services if it cannot carry out KYC identification procedures has been amended to make it clear that services must not be provided if KYC cannot be completed. Further, in those circumstances the reporting entity must lodge a suspicious matter report.

Banking relationships
Section 95 of the Act now prohibits financial institutions from entering into a banking relationship with an institution that permits its accounts to be used by a shell bank, that is a bank that does not have a physical presence in a jurisdiction.

Tipping-off offences
The Amendment to the tipping off offence introduces exceptions to section 123 which now allows disclosure of suspicious matter reports to:

  • external auditors reviewing the AML/CTF program; and
  • designated business group or corporate group members outside Australia, for the purpose of disclosing the risks involved in dealing with a particular customer. 

The section also relaxes the prohibition on disclosing that AUSTRAC or another agency has requested information from the reporting entity.

Access to information
The Act previously 'designated' the agencies which could access and disclose AUSTRAC information and had a narrow definition of AUSTRAC information. Section 125 introduces a general information sharing power which allows Cth, state or territory agencies to access a range of AUSTRAC information and permits disclosure of AUSTRAC information to foreign agencies and governments.

Cross-border movements of money
Section 53 of the Act now requires travellers to report cross-border movements of instruments over $10,000, whether in physical currency or bearer instruments and applies to all laundering methods. Similarly, section 54 requires reporting of instrument receipts for amounts over $10,000 from overseas.

The Amendment also expands section 143 so that the offence of structuring physical currency movements now applies to monetary instruments.

How does this affect you?
You should review your AML/CTF Program to assess whether the new provisions affect your business. If they do, it will be necessary to amend your Program to address the changes.

For reporting entities operating within Australia, the main issues to consider are:

  • whether to amend your Program to permit reliance on KYC procedures performed by third parties under new sections 37A and 37B and section 38; and
  • whether your current Program deals with the prohibition in section 32 which bans providing services where you are unable to complete KYC on a customer.

We recommend completing a review of your Program prior to December 2021 so that any changes can be considered and approved by the Board prior to lodging your AUSTRAC report in March 2022.

 

 

 

Contact Us

Feel free to drop us a message if you have any questions or requests.

Or give us a call at

P: 03 9663 4456

and post us at

P.O. Box 18009
Collins Street East
Melbourne, VIC 8003

We're located at

Level 25, 360 Collins St
Melbourne, VIC, 3000