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Consultation on proposed guidance relating to employee due diligence

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 EDD in the anti-money laundering and counter-terrorism financing (AML/CTF) compliance framework issued for consultation on 3 November 2022 (the Guidance).

The Committee has the following four general comments and observations in relation to the proposed Guidance:

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