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Consultation on proposed guidance on providing financial services to customers that financial institutions assess to be higher risk

This submission is made by the Financial Services Committee of the Business Law Section of the Law Council of Australia (the Committee). The Committee thanks the Australian Transaction Reports and Analysis Centre (AUSTRAC) for the opportunity to comment on the proposed guidance on providing financial services to customers that financial institutions assess to be higher risk issued for consultation on 9 November 2022 (the Guidance).

The Committee commends AUSTRAC for preparing this detailed and nuanced draft guidance on an issue that is of considerable importance to financial institutions and customers, or prospective customers, that the financial institutions assess to be higher risk.

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