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Parliamentary Joint Committee on Law Enforcement
09/09/2014
Financial related crime

BIEYTES CORRO, Mr Eduardo, Managing Director, Ria Financial Services Australia Pty Ltd

NGUYEN, Ms Dianne, Director, Head of Compliance, Eastern & Allied Pty Ltd

YUEN, Mr Crispin, Head of Compliance, Australia and New Zealand, Ria Financial Services Australia Pty Ltd

CHAIR: I now have the pleasure of welcoming representatives from the remittance industry. Do you have any comments to make on the capacity in which you appear?

Ms Nguyen : I am here representing the remittance association.

CHAIR: Thank you. Would you like to make an opening statement before we get to questions?

Ms Nguyen : We would, thank you. On behalf of Crispin, Eduardo, myself and the other entities that contributed to the submission and the members of our association, I would like to thank you for the opportunity to be witnesses here today and to participate in the inquiry. We represent a group of remitters, also known as money transfer businesses, that operate in Australia. By way of background, our organisations provide a financial service that allows our customers to send and receive money internationally. There are 6,000 organisations that are registered and regulated by AUSTRAC in Australia, and they comprise just under 100 networks, 5,500 agents that report to those networks, and 620 independent remitters. Our organisations have duties and obligations under a variety of acts, most significantly the AML/CTF Act, and do the same reporting as discussed in this morning's session with the Australian Bankers' Association. We provide the same intelligence to the law enforcement and other government agencies as per the banks, and no doubt you have questions regarding that. The financial service we provide is different. Our customers use our service for a variety of reasons. Our fees are cheaper. Our exchange rates are better. We offer different types of services. We see a large proportion of our transactions mainly conducted by private customers to support their families from migrant communities, sending funds back home. We also have a range of personal and business customers that transfer for different reasons.

Mr Yuen : You will see a number of responses to the terms of reference in our submission, but the one that we see as the most pertinent and with potentially the greatest impact on financial crime is the debanking of the remittance business. Most of the major banks have decided to not bank remittance business, resulting in remittance business not having bank accounts with which to operate. This is now a pressing issue, because a business without a bank account cannot operate, and three of the four major banks have already said no. The Australian Federal Police and the Australian Crime Commission have real issues about the impact of these transactions going underground and being done by private arrangement in an unregulated, unreported way if the sector loses its banking relationships. We look forward to providing you with information regarding this issue and other items submitted. We thank you in advance.

CHAIR: Eduardo, did you have any further comments?

Mr Bieytes Corro : No.

CHAIR: My first and most important question is: why have the banks taken that stance? What could possibly be their rationale for that.

Ms Nguyen : The sector is deemed to be a high risk. It was unregulated pre-2006. The regulation under the AML/CTF act came in 2006. The proper registration process for organisations to be properly acknowledged with AUSTRAC was in force in 2012. Prior to that there was a variety of organisations that were not registered, a variety of organisations that had varying levels of compliance with the AML/CTF act. The banks have seen this industry as a whole as riskier.

Mr Yuen : You are painting with a broad brush and generalising.

Ms Nguyen : Absolutely. There are rogue organisations within the sector that will fall into that risk category. As of 2014 AUSTRAC are doing a good job of regulating the industry. They know who they are regulating. They do due diligence to ensure that only the right businesses and organisations are operating under the framework.

Mr Bieytes Corro: I have seen the letters and the letters pretty much say the bank have changed their risk appetite and so we are terminating the relationship. That is it; there are no more explanations.

Mr Yuen : There is no background. They just decided to close the bank account. It is happening to not just the remittance agents, the mums and dads who decided to become agents for a remittance network, but it is also happening to larger players as well.

Senator O'SULLIVAN: For my part, that could not explain the banks' attitude. If they were going to do that they would stop punters from banking with them too. What is the risk that they fear? Do they fear you are going to make a transfer you are not going to honour or something? Is there some line of credit arrangement that you have to have to operate this business?

Ms Nguyen : It is probably a couple of things. There have been a couple of instances where, internationally, they are feeling a pressure from a lot of banks that face similar issues. They do not want to be involved in a transaction where down the line one of their customers—being one of the remitters—is involved with a money laundering type of incident or a terrorist incident. We might take on a customer who is a potential terrorist who uses their chain. For that we have controls in place. The other risk they face is that we might do a transaction for a customer that is listed on Department of Foreign Affairs and Trade sanctions or some sort of international sanctions. Again, we have processes in place to meet that requirement.

Senator O'SULLIVAN: You have not considered this as a raw competition issue, have you?

Mr Yuen : Maybe. It could be. You have banks that provide money remittance services themselves.

Senator O'SULLIVAN: I imagine they all provide money for remittance.

Ms Nguyen : They do.

Mr Yuen : Yes. They set the currency exchange rate, they charge the fee and so on. You need to understand; our customers are first or second generation people who are of a particular descent. We live in a multicultural society where we have different people from different heritage. So if they want to send money back home to India to pay living expenses for their parents then that is when they use the money transfer companies. They do not often use the banks.

Senator O'SULLIVAN: Yes, I understand all that. We could spend all day on this alone. Do you know of any other circumstances where the banks have become such good corporate citizens that they have assisted the world to be a better place by limiting or by neutralising banking operations on this front? Or just with international transfers?

Ms Nguyen : At the present, no.

Senator O'SULLIVAN: So they have not stopped taking deposits off people with long hair and marijuana plants tattooed on their forearms but just this?

Mr Bieytes Corro: As far as I know, no.

Mr Yuen : It is like them making a decision to not bank with outlaw motorcycle gangs. They just made a decision to manage their risk. They do not want to put in the effort and it is causing a bit of a problem for the motorcycle gangs.

Senator O'SULLIVAN: But how do they identify an international remitter? Is it just by the volume of traffic in what you are doing?

Ms Nguyen : If you are registered with AUSTRAC then your business is listed on the AUSTRAC website as being registered with them. If they can do a match of the behaviour of your account and look at you as being listed on a list from AUSTRAC then that is how we can be identified.

Mr Yuen : The remittance companies are reporting entities just like the banks. We are all reporting entities within the AML/CTF legislation. Particularly for the remittance sector they need to be registered on the AUSTRAC register, and that gives transparency oversight to manage money laundering, people smuggling and terrorist financing. So, I would ask: why would the banks not be thinking about the ones that are not currently registered, the ones that are rogue and the ones that are not professional?

Senator O'SULLIVAN: Are they denying you a line of credit or are they just denying you the ability to operate an account?

Mr Bieytes Corro: They are closing any bank account that you might have with them.

Senator O'SULLIVAN: So, line of credit and also if you have got—

Mr Bieytes Corro: You can have an operational bank account with them.

Ms Nguyen : No banking facilities at all.

Senator O'SULLIVAN: I am not advocating this, but is it within your bailiwick to be able to establish an operation, say, out of Hong Kong and still continue to do your transfer arrangements while not being registered in Australia as a registered remitter?

Ms Nguyen : Can you repeat the question.

Senator O'SULLIVAN: Pretend I wake up one day and decide that I am going to become a remitter. I am not going to seek registration in Australia under the government's regulations here. I have just decided to establish my banking arrangements somewhere offshore. Could I function efficiently?

Mr Bieytes Corro: Yes, you can. If you do hawala or hundi, yes, you would be able to do it. In that sense, there will not be any real money transfers happening between Australia and Hong Kong. You will just have a bank account there and a bank account here. The money is actually not being transferred. Eventually, you use the banks, if you can, to do a settlement with your counterpart on the other side—but that is unregulated.

Senator O'SULLIVAN: I appreciate that.

Mr Yuen : If we let that happen then the law enforcement agencies will have trouble, because they will have difficulty in tracing the money and following the trail.

CHAIR: Given the inquiries into financial fraud, how were the banks' actions preventing or making it more difficult to deal with the issue of financial fraud, from your perspective, in terms of fraudulent activities through remittance providers rather than through the banks? Does it make it easier or harder for people to do it?

Ms Nguyen : I would say that, at the present time, if you have a banking relationship then the risk of aiding or assisting or being part of financial crime is low because the controls that each of the organisations have in place mean that, just like the banks, we would do the suspicious reporting. We engage with law enforcement in much the same way. When it comes to the currently unregulated sector or if the illegitimate businesses do not have a bank account to operate, that is when you will have a lot of activity go underground and that is when the financial crime will be undetectable or unreported.

CHAIR: If somebody comes to you and wants to transfer money overseas, what are the requirements from your perspective or from the remittance providers' perspective that you represent in terms of identifying that person so that there is a trail of that money? If they went to an ordinary bank, there would be that trail and identification et cetera.

Ms Nguyen : The legislation in Australia requires that we do 'know your customer' and customer identification for every single transaction that goes overseas. So, regardless of whether you were sending $1 or $100,000, we would have to do a report to AUSTRAC, and that automatically triggers if you do a transaction. There are quite strict requirements as to what ID or what information you need to collect from the customer in order to transact to begin with. Then, on top of the reporting requirements, we do transaction monitoring to identify any trends or any suspicious behaviour or any transactions that happen outside the scope of, say, a baker who might earn X amount of dollars and is all of a sudden doing X amount of transactions, with X volume. So we have systems in place to capture the identification, report it, monitor transactions and monitor suspicious behaviour.

CHAIR: You make the comment in your submission about an increase in the prevalence of counterfeit identifications. How much is that impacting on the ability of your members to provide remittance services with a significant level of confidence that a transaction is genuine?

Mr Yuen : We engage very closely with the Crime Commission and the Australian Federal Police, and we get feedback on the street level telling us that this is happening. In order for us to comply or make sure that we take a risk based approach, we want to think about the kinds of controls that we can use to detect fraudulent IDs, particularly from overseas like a passport from a different country. We have put measures in place, at least from our organisation, to ensure that we are prudent in terms of the ID that we collect are those issued from the government and so on. If it is an Australian ID then it is just a matter of making sure the person at the counter is the person they say they are. We collect and we sight the details, and we ensure that we document that in our reports.

Ms Nguyen : AFP officers have told us that you can purchase what is called an ID pack—drivers licence, Medicare card and a bank card as a set of three—with a fake ID and maybe a legitimate address that may effectively be processed through the systems okay, but it is not the right person who it says it is on the ID. We have made a point about the document verification system in our submission. We believe all remitters should use it. At present, there is quite a high set-up fee for the more independent remitters. That potentially should be waived, so we can ensure that every single customer who walks through the door has their ID screened to ensure that the risk that someone is bringing in a fraudulent ID is reduced.

CHAIR: Could you explain how that document verification system works?

Ms Nguyen : Sure. Crispin will walk into our business with his drivers licence and Medicare card. It is simply a matter of entering Crispin's name and the card number or the licence number, and it will return whether it is a fraudulent ID or whether it is verified as a valid and correct ID.

CHAIR: How long does that take?

Ms Nguyen : It is instantaneous. If you enter the details, it is instantaneous.

Mr Yuen : You pay 67c.

Ms Nguyen : Yes, per successful check. It is a very good tool that we believe everyone should use. My understanding from the document verification system's director is that there is a $5,000 set-up fee so that the A-G's can do due diligence on the private organisations that want to use it. We will probably be making a follow-up submission to suggest that that set-up fee should be waived for that usage by remitter organisations and the banks.

CHAIR: We had testimony earlier today that there is an issue between the licensed service providers and the unlicensed service providers. Is that an issue in the remittance industry as well?

Ms Nguyen : Yes.

Mr Yuen : Yes. We want to separate the professionals from the amateurs and the rogue agents.

CHAIR: What legislative oversight is there of the remittance industry? Is it ASIC?

Ms Nguyen : It is AUSTRAC.

CHAIR: AUSTRAC entirely?

Ms Nguyen : Yes.

CHAIR: What enforcement powers do AUSTRAC have in relation to unlicensed remittance providers? When they identify unlicensed remittance providers, are they prosecuting them and putting them out of business?

Ms Nguyen : There are criminal processes that can take place if a remitter is found to be doing business in an unregistered way. My understanding is that no-one has been subject to those criminal proceedings yet. But those organisations definitely exist on the street. We are ultimately competitors as well, but within our organisations we have agents that tell us, 'The guy next door from our business or our office-front is unregistered.'

CHAIR: So if that is reported to AUSTRAC, what enforcement action are they taking to make sure they close them down?

Ms Nguyen : We haven't seen anything published.

Mr Yuen : We have no visibility on that.

CHAIR: You would know if the guy next door to you disappears the next day.

Ms Nguyen : Yes, but we haven't seen—

CHAIR: You don't know and that is AUSTRAC's doing or other—

Ms Nguyen : To be frank, we haven't seen competitors that are operating in that rogue manner shut down.

Mr Bieytes Corro : They are not disappearing.

CHAIR: But they do exist.

Mr Bieytes Corro : They are still there, and we hear on the street from our customers: 'Why are you asking for all this documentation when over there they don't ask for anything? If you want do go there, go.' But they are still there.

CHAIR: If you report something like that to the AFP, do they have any jurisdiction or is it entirely through AUSTRAC?

Ms Nguyen : It is entirely through AUSTRAC is my understanding.

Mr MATHESON: Though your monitoring processes of unusual transactions, has anybody ever been prosecuted?

Ms Nguyen : Yes. The AFP come to visit and talk about cases in declassified terms that we have assisted with where customers of ours have been charged, gone through the court process or been successfully prosecuted?

Mr MATHESON: What types of offences? Is it money laundering? Terrorism.

Ms Nguyen : The ones that I can speak of are money laundering relating to drug trafficking?

Senator O'SULLIVAN: The unlicensed operators—

Mr Yuen : It is not a form of licence; it is a form of registration with AUSTRAC.

Senator O'SULLIVAN: So unregistered operators: are they operating efficiently? Are they providing an efficient competitive service?

Ms Nguyen : Yes.

Senator O'SULLIVAN: So what is the disincentive for them not to be registered?

Ms Nguyen : There are onerous compliance obligations that you have to complete. For an organisation like ours we have to have a compliance program. We have to do the ID checks. We have to do the reporting. There is an annual report—do the suspicious reporting, transaction monitoring, the whole gamut.

Mr Yuen : The whole program.

Ms Nguyen : The other thing is if you are not listed on an AUSTRAC website to say that you are a remitter, then you can have a banking relationship that additionally helps to make that operation easy.

Senator O'SULLIVAN: That is crazy.

CHAIR: So three of the four big banks, you said earlier, are no longer providing banking facilities. What about some of the smaller banks—or don't they have the capacity to provide the facilities that your industry requires?

Ms Nguyen : Our businesses require a broad branch network, because we have got a lot of agents. Those agents need to be able to bank into their local branch, and the smaller regional banks do not have that branch network to be able to do that.

Mr Bieytes Corro : And some of them are also not entertaining MSBs.

Mr Yuen : MSB meaning money service businesses.

Mr MATHESON: You are saying that unregistered remitters can own up a bank account. Wouldn't the banks be doing some sort of reporting on transactions going through those accounts for large amounts of money? Wouldn't they report on that?

Ms Nguyen : Yes, and I have seen one business that has 'trading company' in their business name. If they say they are a trading company importing and exporting, they can use that as the reason why there is a lot of activity happening in and out of their account.

CHAIR: What would the average remittance amount be that somebody would transfer overseas?

Mr Bieytes Corro : For our operation here in Australia, $650.

Ms Nguyen : Ours is $800.

CHAIR: So they are not large amounts of money. How often would people interact with a remittance provider—monthly, weekly?

Mr Bieytes Corro : I would say fortnightly.

CHAIR: What is the general purpose of the remittances? What would be, say, the top three purposes for remittances?

Mr Bieytes Corro : No. 1 is supporting families, so they are sending money to countries where there are economic difficulties. This is money that is going to be used for buying food, supporting schooling and people that are sick—mainly, elderly people. We also have customers who are foreign workers who come here as contract workers. They are going to be here for a period of time, so everything that they make over here, they send home because in two years they are going back and they are going to have the ability to buy a house, a business or something like that. Those would be the two main reasons, the recurring ones.

CHAIR: Out of 100 per cent of your transactions, how much would those two make up?

Mr Bieytes Corro : I would say 90 to 95 per cent. Every once in a while you have somebody who needs help for whatever reason, and then they come in and send a larger amount of money. Those are one-offs. Usually, when you are talking about more than $5,000, it is better to go to the bank because the bank will charge a set fee for doing that. They do not entertain coming to us.

CHAIR: We have had evidence in the last couple of days, particularly, in more remote communities that the use of remittance services is one of the major ways of moving money offshore through a marriage scam or an inheritance scam—any of those phishing-type emails. What responsibility do your organisation or members have, if somebody comes into one of their branches wishing to remit money overseas for that particular purpose, for those owners or managers of those businesses to say something to that person about the possibility that that could be fraudulent. You probably cannot stop people from doing it. It is ultimately their decision, but at least you can give them some sort of warning that it may be for fraudulent purposes and they could risk losing their money.

Mr Yuen : This is really right up my alley, because we deal with consumers—people of your age—who want to send money to a 'fiance' in Africa. When we perform what we call customer due diligence, we identify that something isn't right. We speak to them and they are anxious. We pick this up through conversation when we conduct our customer due diligence. Everything is fine. The source of funds is fine. They have a legitimate source of income. It is not coming from proceeds of crime. Everything is legitimate, but the money is being sent to somebody they have not met face-to-face. We ask a few more questions and, after they are not able to answer and start evading questions, I say, 'Are you going to tell us what it is or we will we just issue you with a refund and cancel the transaction?' They then start telling the truth about what is happening and that they have met the person online. That is when we understand the whole situation. We do a look-back at the transaction history of the customer. We look at the documentation that has been supplied by the customer to prove that this is the person they are sending money to. It can turn out that this is not a real person, because we do a simple image search on Google and find a photograph that belongs to somebody else.

Senator O'SULLIVAN: Why would you care?

Mr Yuen : We are protecting our customers.

Senator O'SULLIVAN: But why? Does that mean you wouldn't sell cigarettes if you had a corner store? It is a legitimate question. I am wondering why you are in that space.

Mr Yuen : We do not want our customers to use our company to do money transfer if they are the victim of a scam. So we encourage them to go to the nearest police station and tell them what happened.

Senator O'SULLIVAN: Is that right across the industry? Do all companies do that?

Mr Bieytes Corro : He is speaking on our behalf, and I am sure she is doing the same.

Senator O'SULLIVAN: A bank teller is not going to through this at one of our major banks, if I am going to transfer money?

Ms Nguyen : No, they won't. We do a lot of training with our staff to talk to them about this sort of stuff. The reason that Crispin provided is that we do not want any sort of criminal activity going through our business. We just want to operate our business for legitimate customers. If a customer insists on doing the transaction, Ria might say no. Other organisations might say yes, providing that they give a warning to the customer.

Senator O'SULLIVAN: But this is an altruistic service you are providing. This isn't—

Ms Nguyen : This is not a requirement.

Senator O'SULLIVAN: This is just good business practice: you don't want criminal activity coming through. You have got no regulatory obligation.

Mr Bieytes Corro : We are an international money remitting company—I am talking about Ria. In the United States, there have been companies that were wilfully looking the other way. In this particular case that you guys are talking about, once it was demonstrated that they were looking the other way, they were fined hefty sums of money. So we do not want to go that way.

Mr Yuen : That is right. That is not the way to go. Whatever is happening here in Australia, the US or the UK, that is not the kind of practice that we should allow here.

CHAIR: What would be the penalty here in Australia in a similar situation to the US if your organisations were being found to do that? Is there any civil or criminal penalty applicable if you were doing that? Or is it just the reputational risk or damage of being publicly made aware?

Mr Bieytes Corro : I do not know.

Ms Nguyen : I believe it is only the reputational risk that we face.

CHAIR: Which would be different if it were a money-laundering or terrorism-financing venture—

Mr Yuen : Yes. I was just going to say that.

CHAIR: There would be civil penalties.

Mr Yuen : That is right. So the legislation is prescribed in that way. It is not designed to prevent fraud, or whatever the things that you see from the ACCC's report on scams. But, if you are an organisation operating in this country, there must be some form of—what is that phrase?—to be able to demonstrate that you are doing the right thing for your organisation.

Senator O'SULLIVAN: I am not sure that we need to spend a lot more time, but translate that to Australia Post. I take a parcel in that is going to Somalia—or Lilliput; let's not pick a country—and inside it is there is something responding to a scam. Australia Post does not take the slightest bit of interest. I am no lawyer, but I would not think that they would have any civil obligation or statutory or regulatory obligation or exposure to penalty if they remit that parcel. Where I am trying to go with you is: there is no regulatory environment at the moment that would punish you if you did not do these things. This is just pure good business, clean shop.

Mr Bieytes Corro : Yes.

Ms Nguyen : Yes. And I guess the other thing is, we have a tough enough time doing business in Australia without being linked to any sort of scam or any sort of financial crime or other crime. We do want to just operate a good business here.

CHAIR: Then why do they think that these independent registered operators are somehow cloudy outfits, whereas traditional banks and financial institutions are not? How is this distinction made? Is there some historical backdrop to this?

Mr Yuen : I think that they do not have visibility on tracking on the money trail. With some of the remittance companies, particularly when they are not using banks, there is no ability for them to be able to distinguish where the money is going to and where the money is coming from. So when they decided to close the bank accounts is when they decided to de-bank or de-risk. It is like them deciding not to provide a service to politically exposed persons.

Senator O'SULLIVAN: I do not want to keep banging on here, but you keep using the word 'de-risk' to the bank. Yet there has been no risk articulated, other than perhaps the National Bank were involved in a transfer made by a private remitter and the money went to a terrorist organisation. Is that the total risk?

Mr Bieytes Corro : No.

Mr Yuen : No. Maybe I will use examples. You have people who supply or do importation of methamphetamine, or manufacture methamphetamine. So they want to wash the money. This is not my own words; this is input from the AFP and the Crime Commission, because I talk to them all the time. These are people who send a bunch of students to come into Australia, with the ID pack—Medicare card, driver's licence, passport, bank card. They come into Australia. They send out the army to all the remittance companies—

Ms Nguyen : And the banks.

Mr Yuen : And the banks. They go to the banks.

Ms Nguyen : And they basically put cash through the system.

Mr Yuen : And they wash the money. Those are professionals. Those are not the people committing the crime; those are the people who are—

Ms Nguyen : Hired to move the money offshore.

Mr Yuen : The professional launderers.

Senator O'SULLIVAN: But there would be millions going through the bank system every day, undetected, for laundering money.

Ms Nguyen : Yes.

CHAIR: So the de-banking—the steps that banks have taken to prevent you having bank accounts—from where I sit, appears to actually increase the risk in the system, rather than reduce it.

Ms Nguyen : Yes.

Mr Bieytes Corro : We believe so.

Ms Nguyen : We believe so also. We have a subset of unregistered remitters now. If the registered remitters do not have bank accounts, we will close up shop, and a new flurry of unregistered remitters will come to fill the space that the registered remitters—

Mr Yuen : The demand.

Ms Nguyen : The demand. And so then you have got—the intelligence that goes with law enforcement does not exist anymore.

CHAIR: And they do not have any concern about what reason money is being remitted for, either. So some of those discussions, that you have outlined to me, that some of your officers may have—about a marriage scam or a phishing scam of some sort—are much less likely to happen with an unregistered—

Ms Nguyen : There are organisations that say, 'If you come to me you don't have to provide any ID.'

Mr Yuen : Yes; they say, 'Don't worry about ID.'

Senator O'SULLIVAN: In Queensland there has been evidence coming out in the last 12 or 18 months about banks lending tens of millions of dollars to what are now regarded as 'organised crime outfits'—code for bikie organisations. They have borrowed tens and tens of millions of dollars from banks to build the amphetamine labs, and the equipment therein, so that they can operate. Yet the bank has not obviously decided, over time, that that is a risk.

Your example was about laundering money. But they have done it right out in the open for a long, long time. This bank policy borders, a bit, on the bizarre, for me. It seems to be anticompetitive. I just do not know of the basis. I want to be certain of the facts because the chair has alluded to the fact, in his line of questioning, that this is probably a serious piece of space that we need to look at with a view to recommendations. I just want to be certain that we are leaving with as much information about why the banks are motivated to do this, and not have the banks tells us, 'Hold on; there's a whole other reason involved.'

Ms Nguyen : It is an international trend. In other countries where this sort of thing has started to happen there are banks that will continue to bank remitters with the view of making sure that there is extra due diligence of those remitters. That is not something that we would be afraid to provide; it is just additional work for the banks.

Potentially, if you are the only bank banking remitters who have a big number of organisations that will bank with you. So commercially, maybe, it is advantageous for you.

Senator O'SULLIVAN: So, it is not a financial risk they are dealing with; it is a reputational risk.

Mr Bieytes Corro : I repeat what I said before. I have seen the letter. The letter said that the bank has changed the risk appetite, so we are asking you to close all of your accounts. You have 30 days or 60 days to take everything out of our bank—

Senator O'SULLIVAN: Yes. So it is not a financial risk. That is my question.

Mr Bieytes Corro : They do not say that. They say, 'We've changed our risk appetite.'

Mr Yuen : I can show you a copy of the letter if you like.

CHAIR: If you could provide the committee with a copy of the letter that would be terrific.

Ms Nguyen : I will say that the financial risk comes back to the fact that if they are seen to be banking someone that is on a sanctioned list somewhere then they, as an organisation, will be fined.

CHAIR: I am conscious that we have others here waiting, but who does that risk lie with, because, at the end of the day, if somebody is on a sanction list, if they bank direct with the bank I can well understand that that is the banks responsibility.

Ms Nguyen : Yes.

CHAIR: However, if they deal through you, it would be my understanding that you are responsible and it has nothing to do with the banks. You are just a bank client. Is that correct?

Ms Nguyen : Yes.

Mr Yuen : That is correct.

Ms Nguyen : The other element is that we are legislated to screen for those sanctioned customers so that we do not provide services to those customers.

Mr Yuen : We are no different from the banks. We perform the same procedure: we screen names. We check against the date of birth, country of birth and so on.

CHAIR: I do not think we have any more questions but I am sure we might think of some more.

Senator O'SULLIVAN: There are thousands more, but no time to ask them.

CHAIR: Thank you so much for coming in today. It is greatly appreciated. A copy of the Hansard transcript will be made available for you to check and you can come back to us with any corrections.

Could we get a copy of that letter, if it is available? We are happy to receive any additional information that you wish to send to us. Just send it in to the secretariat.

Ms Nguyen : Sure. There will definitely be a follow-up.

CHAIR: Thank you for coming in.