AP GROUP ANTI-MONEY LAUNDERING AND COUNTER-TERRORISM FINANCING (AML/CTF) POLICY
OUR COMMITMENT
AP Group is committed to maintaining the highest standards of professional integrity and complying with Australia's anti-money laundering and counter-terrorism financing (AML/CTF) laws.
This Policy applies to services provided by AP Group, including AP Legal and AP Sales.
As part of our legal and regulatory obligations, we undertake customer due diligence and maintain systems and procedures designed to identify, assess and manage the risks of money laundering, terrorism financing, fraud and other financial crime.
CUSTOMER IDENTIFICATION
Before providing certain services, we may be required to verify the identity of our clients and other persons involved in a transaction.
Depending on the nature of the engagement, we may request:
- photographic identification (such as a passport or driver's licence);
- proof of residential address;
- company, trust or partnership documentation;
- details of directors, shareholders, trustees, beneficiaries and ultimate beneficial owners;
- documents establishing authority to act (including powers of attorney, corporate authorities, grants of probate or letters of administration); and
- any other information or documentation reasonably required to comply with applicable laws.
We may also verify identity electronically using reputable third-party verification providers.
CUSTOMER DUE DILIGENCE
Our obligations extend beyond verifying identity.
Where appropriate, we may also be required to:
- query the purpose and nature of a transaction;
- verify the ownership and control of companies, trusts and other entities;
- identify ultimate beneficial owners;
- verify the authority of persons acting on behalf of others;
- undertake sanctions and politically exposed person (PEP) screening;
- obtain information concerning the source of funds or source of wealth where appropriate; and
- conduct ongoing monitoring throughout our engagement.
The extent of these enquiries will depend upon the nature of the transaction and the level of risk identified.
ELECTRONIC VERIFICATION
To assist us in complying with our legal obligations, we may engage reputable third-party providers to conduct electronic identity verification, sanctions screening, politically exposed person screening, company and trust searches, beneficial ownership verification and other compliance checks.
By engaging AP Group, you authorise us to undertake such enquiries where reasonably required.
INFORMATION SHARING WITHIN AP GROUP
Where permitted by law, information obtained as part of our customer due diligence processes may be shared between AP Group entities, including AP Legal and AP Sales, for the purposes of complying with applicable AML/CTF laws, avoiding unnecessary duplication of identification procedures and facilitating the provision of professional services.
We will only use and disclose your information in accordance with applicable laws and our Privacy Policy.
To the fullest extent permitted by law, AP Group, its related entities, directors, employees and agents will not be liable for any loss, damage, cost, delay or expense arising directly or indirectly from any action taken or omitted in good faith to comply with applicable laws or regulatory obligations
EXISTING CLIENTS
Even if you have previously provided identification or other information to AP Group, we may be required to obtain updated identification or further information where required by law or where the nature of a transaction or our legal obligations change.
DELAYS AND FAILURE TO PROVIDE INFORMATION
To minimise delays, we encourage clients to provide all requested information promptly.
If required information or documentation is not provided, we may be unable to commence acting, continue acting or complete a transaction.
Where necessary to comply with our legal obligations, we reserve the right to decline instructions, suspend work or terminate our engagement.
CONFIDENTIALITY AND PRIVACY
Information collected for AML/CTF purposes will be handled in accordance with applicable privacy laws and AP Group's Privacy Policy.
We retain records only for the periods required by law and take reasonable steps to protect personal information from unauthorised access, misuse or disclosure.
OUR LEGAL OBLIGATIONS
Australian AML/CTF legislation requires reporting entities to undertake customer due diligence, maintain records and, in certain circumstances, report suspicious matters to the relevant authorities.
Our legal obligations may prevent us from explaining why particular information has been requested, why additional enquiries are necessary or why we are unable to continue acting in a particular matter.
We may be required to make enquiries, obtain further information or documentation, delay or decline to proceed with a transaction, suspend or terminate our engagement, or take any other action reasonably necessary to comply with our legal obligations.
To the fullest extent permitted by law, AP Group, its related entities, directors, employees and agents will not be liable for any loss, damage, cost, delay or expense arising directly or indirectly from any action taken or omitted in good faith to comply with applicable laws or regulatory obligations.
QUESTIONS
If you have any questions regarding this Policy or our AML/CTF obligations, please contact us.
We will be pleased to explain our requirements and processes wherever we are legally permitted to do so.
Last Updated: 30 June 2026
