Legal

Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Program

The AML/CTF Act 2006, which was recently amended, ensures that Australia’s AML/CTF regime can effectively deter, detect and disrupt money laundering and terrorism financing. 

Suncorp Bank takes the implementation of the AML/CTF Act seriously and has taken steps to ensure that we meet our obligations as set out in the AML/CTF Act and the AML/CTF Rules. 

Current Commonwealth legislation dealing with AML/CTF includes: 

  • The AML/CTF Act and the AML/CTF Rules; 
  • Proceeds of Crime Act 2002; 
  • Criminal Code Act 1995; 
  • Charter of the United Nations Act 1945. 

Key components of Suncorp Bank’s responsibilities are set out in our AML/CTF Program

Reporting Group

Norfina Limited and its subsidiary, Norfina Advances Corporation Pty Ltd (together known as Suncorp Bank), provide designated services and are members of the ANZ Reporting Group. 

Oversight by Board and Senior Management

Suncorp Bank's AML/CTF program has been approved by the Suncorp Bank Chief Risk Officer, with ongoing oversight by the Suncorp Bank Boards, Senior Management and Line of Business reporting structures.

AML/CTF Compliance Officer and Senior AML/CTF Approvers

Suncorp Bank has appointed an AML/CTF Compliance Officer at management level who has the responsibility for the AML/CTF Program, and Senior AML/CTF Approvers who make decisions on matters such as Politically Exposed Persons (PEP), Nested Services Relationships and Third-Party management.

Employee Training

Suncorp Bank has AML/CTF Risk Awareness Training in place to enable staff to understand the obligations, the risks, the consequences of non-compliance and the procedures and processes in place. This training is undertaken on a recurring cycle or when legislative change dictates.

Personnel Due Diligence

Suncorp Bank has procedures and processes in place to ensure that initial and ongoing due diligence is carried out for personnel, to mitigate the risk of personnel using their position to facilitate money laundering or terrorism financing.

Independent Evaluation of our AML/CTF Program

Suncorp Bank's AML/CTF Program is subject to independent evaluations conducted by our Internal Audit department or independent external parties to assess the effectiveness of our risk-based controls and compliance with the AML/CTF Act and Rules. Independent evaluations occur at a minimum every three years. Reports are provided through to the Suncorp Bank Boards, Senior Management and the Audit Committee.

Record Keeping

Suncorp Bank has implemented processes and procedures to ensure that records made in respect of customer identification are held for 7 years after the end of the relationship. Other documentation will be retained for the length of time required to meet our legislative obligations.

Know Your Customer

Suncorp Bank introduced a risk-based methodology based on the requirements of the AML/CTF Act and Rules to collect and verify certain information to identify a customer and any related parties where necessary. In most cases, this will occur at the point of time of onboarding a new customer or entity. Controls, processes and procedures have been developed to capture this information based on Suncorp Bank’s risk tolerance.

Suspicious Matter Reporting

Suncorp Bank has implemented controls, processes and procedures to detect and report suspicious activities and transactions to AUSTRAC.

Transaction Reporting

Suncorp Bank is required to report to AUSTRAC the following transactions and has developed the controls, processes and procedures to submit those reports: 

  • All inward and outward International Funds Transfer Instructions to transfer money into or out of Australia, in the format as required by AUSTRAC; 
  • All threshold transactions where the interaction involves cash amounts of $10,000.00 or more, in the format required by AUSTRAC. 

Sanctions

Suncorp Bank has implemented controls and processes to monitor customers and transactions against prescribed lists.

Suncorp Bank must comply with Australia’s sanctions laws, which prohibit or restrict Suncorp Bank from engaging in activity that involves sanctioned persons in, and prohibited activity with, certain jurisdictions. Suncorp Bank’s policy is to also observe some international sanctions regimes.

Countries to which Suncorp Bank will not send payments

To mitigate against the risk of contravening sanctions laws or regimes: 

a) Suncorp Bank will not send payments to Iran, Syria, North Korea, Cuba and the occupied regions of Ukraine including but not be limited to Crimea, Donetsk, Sevastopol and Luhansk; 

b) Except in limited and pre-approved circumstances, Suncorp Bank will not send payments to Afghanistan, Burundi, Central African Republic, Congo (the Democratic Republic of the), Guinea- Bissau, Iraq, Lebanon, Libya, Myanmar, Russia, Somalia, South Sudan, Sudan, Venezuela, Yemen, and Zimbabwe;

c) Except in limited and pre-approved circumstances, Suncorp Bank will not send commercial payments that have any connection directly or indirectly with Belarus or the Ukrainian Territories of Kherson or Zaporizhzhia. 

Suncorp Bank customers must ensure that none of their transactions directly or indirectly involving sanctioned persons or prohibited activity are sent to or processed through Suncorp Bank. Suncorp Bank will take appropriate action, including potentially blocking transactions (i.e. freezing) or rejecting transactions, to protect Suncorp Bank’s legitimate interests of mitigating against the risk of sanctions violations. 

Correspondent Banking

Suncorp Bank has implemented processes and procedures to ensure that we will:

  • Not conduct business with shell banks
  • Not offer pay through accounts
  • Conduct regular due diligence reviews of our correspondent bankers to understand their AML/CTF policies and controls 

Administrative Information for Correspondent Banking Due Diligence

Operating Banking Entity: Suncorp Bank (Norfina Limited ABN 66 010 831 722 AFSL No 229882) (Authorised Deposit-taking Institution)

Registered Address: Level 9, 833 Collins Street, Docklands VIC 3008

Stock Exchange: Australian Securities Exchange (ASX)

Regulators

Australian Transaction Reports and Analysis Centre (AUSTRAC) - Australia's AML/CTF regulator and financial intelligence unit. 

Australian Prudential Regulation Authority (APRA) – Australia’s prudential supervisor, responsible for ensuring that Australia’s financial system is stable, competitive and efficient. 

Australian Securities and Investment Commission (ASIC) – Australia’s integrated corporate, markets, financial services and consumer credit regulator. 

Contact Details

AMLCTFCompliance@suncorpbank.com.au

USA PATRIOT Act Certificate

In accordance with the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (USA PATRIOT ACT) Act 2001, financial institutions in the United States are required to obtain certain undertakings and maintain certain records about banks outside the United States with whom they maintain correspondent accounts. 

Suncorp Bank (Norfina Limited ABN 66 010 831 722 AFSL No 229882) has prepared a global certificate setting out this information. The Global Certificate is intended for use, and may be relied upon, by any financial institution requiring a USA PATRIOT ACT Certificate from Suncorp Bank. 

Suncorp Bank is authorised by the Australian Prudential Regulation Authority (APRA) in Australia to carry out banking business in Australia. 

If you have any questions, please submit an enquiry to AMLCTFCompliance@suncorpbank.com.au. 

Download a copy of the USA PATRIOT Act Certificate

AML/CTF Questionnaire

The AML/CTF Wolfsberg Questionnaire is available upon request to the financial institutions we work with. Please contact AMLCTFCompliance@suncorpbank.com.au for assistance.