Issues Paper AML/CTF Act Review

February 25th 2014

Issues Paper – AML/CTF Act Review Legislative Review and Mutual Evaluation Criminal Law and Law Enforcement Branch Attorney-General’s Department 4 National Circuit Barton ACT 2600 by email to am l r e v i e w @ ag . g ov . au

Thank you for the opportunity to comment on the Issues Paper dated December 2013 relating to the Review of the AML/CTF Regime.

Universal Gift Cards Pty Ltd supplies prepaid cards to corporate clients so they can reward their customers or staff or resellers. Additionally a small part of our business is supplying prepaid cards to consumers who buy them on our website.

One observation and two suggestions:

Harnessing technology (pages 19 – 20)

We applaud the development and use of online identity verification systems.

Minimising regulatory burden on reporting entities (pages 16 – 17)

We advocate the elimination of the requirement for ongoing ID of corporate clients buying prepaid cards if our corporate client can reasonably be assessed as “low-risk”.

Thresholds (pages 25 - 26)

The manner in which thresholds are expressed causes us and our clients some inconvenience. They are expressed in the form “$x or more”. Thus we are obliged to set peculiar limits like $499.99 or $9,999.99 in our systems and in our product literature if we wish to design our product to enjoy a lighter regulatory regime.

Universal Gift Card Pty Ltd ABN 25 092 828 772 Phone (02) 9352 3888 w w w . uni v er s algi f tc a rd . c o m . au 145 Darling Street Balmain NSW 2041 Our clients want to load round or tidy amounts like $20 or $50 or $100 or $500 or $1,000 or $10,000 to our cards. In cases where the value load is on the cusp of the AML/CTF threshold, one cent makes a big difference!

We advocate that either (a) all AML/CTF thresholds be adjusted upwards by one cent by expressing them in the form “more than $x”; or (b) AML/CTF thresholds be adjusted upwards by one cent by expressing them in the form “more than $x” for prepaid cards only.

Yours faithfully

Peter Hamilton Group General Manager Universal Gift Card Pty Ltd

Universal Gift Card Pty Ltd ABN 25 092 828 772 Phone (02) 9352 3888 w w w . uni v er s algi f tc a rd . c o m . au 145 Darling Street Balmain NSW 2041