Question 1
What new ML/TF risks might arise for a small regional Australian bank that services customers face-to-face at its branches if, as part of an initiative to grow the business, it introduces an online banking capability allowing clients to apply and transact completely online? What controls could the bank implement to manage one or more of the new ML/TF risks you identified?
Question 2
What is a possible change to the financial services industry (in Australia or globally) that may increase ML/TF risk and necessitate changes to controls? What is the significance of this change to the industry and what AML/CTF controls could be applied? What would be the likely impact of the application of such controls?