AUSTRAC: Guidance on assisting customers who don’t have identification
This is a joint submission made on behalf of:
•Consumer Action Law Centre
•Financial Counselling Australia
•Financial Rights Legal Centre
•Indigenous Consumer Assistance Network
•Mob Strong Debt Help
•Super Consumers Australia.
Our organisations welcome the opportunity to provide feedback on the proposed changes to the AUSTRAC guidance on assisting customers who don’t have identification.
As a collective our organisations have considered this response as either First Nations organisations, First Nations individuals and/or as specialists working with and supporting First Nations consumers across Australia. We acknowledge AUSTRAC’s continued engagement and consultation in line with Closing the Gap priority reform 3 and therefore urge AUSTRAC to consider the recommendations included in this submission as designed to support Financial Service Providers (FSPs) in improving engagement and outcomes for First Nations peoples.
Our submission opens with general comments on the proposed changes, as well as our experience of how banks, superannuation funds and financial institutions have (or have not) applied the Current Guide since we last provided input on its review in 2022.
We also provide feedback and recommendations on specific sections of the draft changes, as well as a response to the guiding questions proposed as part of the consultation process. Finally, we provide case studies to illustrate the ongoing challenges that consumers and their advocates continue to face attempting to have their identities verified using non-standard forms of identification, particularly when it comes to identifying people experiencing vulnerable circumstances.
Read the full submission PDF.
Submission to AUSTRAC_guidance for customers who dont have standard identification_CALC_Ican_FCA_SCA_MobStrong