Austrac has issued a draft amended guidance note 08/01 giving more details of when it will issue a no action letter rather than grant an exemption request for a breach or anticipated breach of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 .
In revised section 4 of the draft amended guidance note it discusses 3 scenarios and whether a no action letter or an exemption request would be more appropriate:
A reporting entity experienced an impractical outcome resulting from an interaction between the FTR Act and the AML/CTF Act.
During an audit in July 2008, a reporting entity became aware of deficiencies in the customer identification process it had applied to customers of about 200 transactions (from a total of several thousand transactions).
A reporting entity was winding down its business in December 2007 when the AML/CTF program obligations came into effect.