Submission: Reforming Australia’s anti-money laundering and counter terrorism financing regime

ARITA made a submission to the consultation in respect of reforming Australia’s anti-money laundering and counter-terrorism financial regime focusing on insolvency and business restructuring as a “proposed designated service 3.”

We submitted that there is no need to impose additional regulatory burdens on insolvency practitioners. The submission set out information on the following, supporting why further regulation is not required beyond that that naturally related to the businesses under control of insolvency practitioners and will provide no benefit to the creditors that bear the cost of the insolvency process nor contribute to the economy-wide benefits of an efficient insolvency system:

• the services that insolvency and business restructuring practitioner provide, and the types of transactions undertaken during the provision of those services,
• key risk areas that may be considered to arise in relation to these services,
• the materiality (or lack thereof) of these risks, and
• risk mitigation that is already undertaken by insolvency practitioners.