ING DIRECT Customer Identification Procedures for Brokers

Transcription

1 ING DIRECT Customer Identification Procedures for Brokers Managing obligations of the Anti-Money Laundering and Counter-Terrorism Financing Act ( AML/CTF Act ) for the purpose of Customer Identification Procedures carried out as an agent of ING DIRECT. February 2014

2 Table of contents 1 Glossary of Terms Introduction Responsibilities of agents of ING DIRECT AML/CTF Act Purpose of this manual Application Process Conduct Standard Identification and Verification Individuals Companies Trusts Broker assesses product and jurisdiction risk Product Risk Jurisdiction Risk Conduct Enhanced Identification and Verification Broker assesses customer risk as higher than standard ING DIRECT assesses customer risk as higher than standard Submit loan application, Identification Form and copies of identification Training Initial MFAA Training FBAA Training Frequency of training Screening Record Keeping Suspicious Matter Reporting Guidelines to trigger suspicions Tipping off Where do I go to get clarification on an AML/CTF question? Appendix A: Identification Form (all States except Western Australia and South Australia) Appendix A1: Identification Form (Western Australia only) Identification Form (South Australia only) Appendix B: Verifying your Identity Appendix C: Company & Trust Appendix...24 Page 2 of 15

3 1 Glossary of Terms Term Accredited Introducer AML/CTF Act 2006 Broker Identification Identification Form MFAA/FBAA/FPA Money Laundering Politically Exposed Person (PEP) Real Property Act Reporting Entity SA Meaning An introducer who has been accredited with ING DIRECT to introduce home loan customers. The Anti-Money Laundering and Counter-Terrorism Financing Act, which was passed in 2006 and which is being implemented under a staggered implementation regime. The Introducer, its Agent or Intermediary linked to the Introducer with ING DIRECT as defined in the Introducer Agreement A process to collect information from a customer that assists in understanding who they are. The form released by ING DIRECT is to be used when interviewing a customer face to face. This form outlines the procedure for brokers to follow to appropriately identify and verify potential customers who are individuals. This form (at Appendix A) must be completed before a loan can be approved. Mortgage & Finance Association of Australia Finance Brokers Association of Australia Financial Planning Association Money Laundering (ML) is the processing of criminal profits to disguise their illegal origin. Money laundering can be used to hide the proceeds of serious crime such as drugs trafficking, weapons dealing and people smuggling or other less serious crimes such as tax evasion and fraud. A politically exposed person is an individual who has been entrusted with prominent public functions in a foreign country, for example Heads of State or of Government, senior politicians, senior government, judicial or military officials, senior executives of state owned corporations, important political party officials. The definition may also extend to family members or close associates of politically exposed persons. This definition is not intended to cover middle ranking or junior individuals in the above mentioned categories. Prescribes the reasonable steps that a mortgagee must take to confirm the identity of the Mortgagor. A business that is captured by the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 as they offer one of the described designated services. South Australia SA VOI Requirements South Australia Registrar-General s Verification of Identity Requirements SSU Terrorism Financing Verification Verifying your Identity Form Not Applicable for applications with security properties in Western Australia and South Australia WA Sales Support Unit, ING DIRECT, GPO Box 4094, Sydney NSW 2001 Includes the financing of terrorist acts, and of terrorists and terrorist organisations. Financial Institutions already have legal obligations preventing us from dealing in any way, with known terrorists. A process to verify the identification information provided by a customer, traditionally undertaken through the collection of identification documents but can also be done through electronic data. An ING DIRECT form which outlines the procedure for customers to follow to appropriately identify themselves when Brokers are unable to meet with the customer face to face. The form (see Appendix B) and original certified identification documents are to be forwarded by the Broker to the SSU for verification. Western Australia WA VOI Requirements Western Australia Registrar and Commissioner of Titles (Landgate) Verification of Identity Requirements. Page 3 of 15

4 2 Introduction The AML/CTF Act 2006 imposes various obligations on Reporting Entities such as ING DIRECT including identifying, managing and mitigating the money laundering and terrorist financing risk that ING DIRECT may reasonably face in relation to the provision of designated services to its customers. The Real Property Act outlines the reasonable steps that a mortgagee must take to confirm the identity of the Mortgagor (customers) prior to settlement of the home loan. Whilst the Real Property Act outlines identification requirements, in Part 3A it also provides the Mortgagee with the option to identify customers by following AML/CTF Act Identification process as outlined in Chapter 4. ING DIRECT has opted to follow the AML/CTF identification procedures as outlined in this document. 2.1 Responsibilities of agents of ING DIRECT As an accredited introducer of ING DIRECT, you are authorised to perform customer identification under the AML/CTF Act and other applicable laws on our behalf as our agent, on the basis that you do so in accordance with the procedures set out in this document and any other relevant procedures specified by ING DIRECT. The Broker referred to in this document means the Introducer, its Agent or Intermediary linked to the Introducer with ING DIRECT as defined in the Introducer Agreement. 2.2 AML/CTF Act Section 37 of the AML/CTF Act states that a reporting entity may authorise another person to be its agent for the purposes of carrying out customer identification procedures on its behalf. As a result a reporting entity may authorise a person to be its agent for the purposes of carrying out the applicable customer identification procedure in respect of the customer on the reporting entity s behalf. 2.3 Purpose of this manual The purpose of this manual is to: a) Set out procedures under the Introducer Agreement that you must comply with for the purposes of compliance with the AML/CTF Act, and other prescribed requirements including the WA VOI Requirements and the SA VOI Requirements; b) Specify training that the Introducer and each of its agents and intermediaries must undergo. The procedures including revised customer identification procedures apply to all customers introduced to ING DIRECT on and after 1 April Page 4 of 15

5 3 Application Process The following diagram represents the customer identification process to be undertaken by the Broker on behalf of ING DIRECT. Each section of this diagram is explained in further detail throughout this guide. Customer wishes to apply for an ING DIRECT home loan YES Will the customer's identity be verified during a face to face interview? NO If the security property is located in WA or SA: Broker is to refer to their BDM or RM Broker conducts face to face identification using prescribed Identification Form depending on the location of security property (Refer Appendix A & Appendix A1) Broker is unable to complete face to face identification e.g client is interstate, or the broker is submitting a loan for themselves, a partner, spouse or dependent. Customer to complete Verifying Your Identity Form and forward the original form and orginal certified documents to the Broker Broker assesses product and jurisdiction risk Based on industry MFAA training Conduct enhanced identification and verification. YES Does the customer present a higher risk? NO Conduct standard identification and verification Submit loan application, prescribed Identification form and legible copies of all identification to ING DIRECT. If the security property is located in a State other than WA or SA, and the Broker is unable to complete face to face identification the original Verifying your Identity form along with original certified documents should be forwarded to Sales Support Unit for verification. Upon receipt of the application, ING DIRECT will assess customer risk and may request additional information. Any suspicious matters should be escalated to ING DIRECT Financial Crimes immediately. Page 5 of 15

6 3.1 Conduct Standard Identification and Verification The objective of the identification procedure is to determine if the customer is the person or entity they claim to be. Standard identification procedures are different depending on the customer type. ING DIRECT deals with the following customer types: Individuals and Sole Traders Companies Trusts Partnerships Associations Individuals The following procedure should be applied to individual borrowers, guarantors, authorised signatories and agents such as persons acting under authority of a Power of Attorney Identification For the purposes of identification under the AML/CTF Act, a customer s application for a home loan cannot proceed unless at a minimum, the following information is provided for each loan applicant who is an individual: Full name and/or Residential address Date of Birth In addition, if the customer is applying as sole trader, we also require: Full business name Full business address (or residential address) Australian Business Number (Additional information will be collected as part of credit assessment procedures however the information above is mandatory for every application.) Verification when conducting a face to face interview all States except WA and SA ING DIRECT has developed an Identification Form see (Appendix A) to be used if the security property is located in a State other than WA or SA. Brokers can use the Identification Form in Appendix A to enable brokers to easily satisfy the verification of customer s identity. To correctly complete the form, follow the steps below: 1. Record details of the person being identified (including all of the details in above) 2. Collect the required identification documents (originals only) and make a copy of them 3. Record the identification documents provided and verify the customer's name and either the customer s residential address or date of birth from the required identification documents 4. Sign the form 5. Provide a copy of the customer's original identification documents and the completed Identification Form to ING DIRECT. Please note: Brokers cannot identify themselves, their spouse, partner or a dependent. If the security property is located in a State other than WA or SA, the documents that can be used to verify the identity of a customer are described in the list below. You must sight and copy either: a) One original photographic identification documents from List A; or b) One original non-photographic document from List A and one original document from List B. Page 6 of 15

7 List A An Australian Passport (either a current passport or a passport that expired within the last 2 years) A current Drivers Licence (which shows a photograph) International Passport or identity card (must be issued by a foreign Government, the UN or related agency and must be accompanied by a translation if not in English) A Birth Certificate or Birth Extract (issued by a State or Territory in Australia) A Citizenship Certificate (issued by the Commonwealth of Australia) List B A current Pension Card (issued by Centrelink entitling financial benefits) An Australian Tax Office Tax Assessment Notice (issued in the last 12 months and shows current residential address) A water rates or council rates notice (issued by a local government body or utilities provider within the last 3 months and shows current residential address) A landline telephone, gas or electricity notice (issued by a utilities provider within the last 3 months and shows current residential address) A government financial benefits notice; e.g. Centrelink (issued in the last 12 months and shows current residential address) Verification when conducting a face to face interview all States except WA and SA ING DIRECT has developed an Identification Form (Appendix A1) to be used if the security property is located in WA. Note: The Identification Form in Appendix A1 can only be used if the customer is in Australia. If the customer is outside Australia, the verification of the customer s identity must be conducted by an Australian Consular Officer. To correctly complete the form, follow the steps below: 1. Record details of the person being identified (including all of the details in above) 2. Collect the required identification documents (originals only) and make a copy of them 3. Record the identification documents provided. Verify the customer against the required identification documents produced, including the customer's name and customer s residential address or date of birth. 4. Sign the form, including the confirmation that you conducted a face to face verification in your customer interview. 5. Provide a copy of the customer's original identification documents and the completed Identification Form to ING DIRECT. Please note: Brokers cannot identify themselves, their spouse, partner or a dependent. If the security property is in WA, the documents that can be used to verify the identity of a customer are described in the list below. You must sight and copy either: 1. The customer should produce CATEGORY 1 documents, if these have been issued to the customer; 2. If the customer does not have the CATEGORY 1 documents, they can produce CATEGORY 2 or 3 documents. 3. The customer should only produce CATEGORY 4 documents, if they are a foreign national and cannot produce the identification documents in CATEGORIES 1, 2 or 3. If any of the required Identification documents are not in English, they must be accompanied by an English translation. Identification documents required for loan applications that contain West Australian properties. Page 7 of 15

8 Category 1 Category 2 Category 3 Category 4 Australian Passport Australian Passport Australian Drivers Licence; Australian Proof of Age Card with photo Foreign Passport with Australian Visa Australian Drivers Licence Australian Proof of Age Card with photo Birth Certificate Citizenship Certificate Australian Drivers Licence Australian Proof of Age Card with photo Birth Certificate Citizenship Certificate A Rates Notice issued in the last 12 months Medicare card Centrelink card Department of Veteran Affairs (DVA) card Medicare card Centrelink card Department of Veteran Affairs (VDA) card Australian Drivers Licence Foreign Drivers Licence (if required) Change of Name Marriage Certificate Change of Name Certificate (if required) Change of Name Marriage Certificate Change of Name Certificate (if required) Change of Name Marriage Certificate Change of Name Certificate (if required) Change of Name Marriage Certificate Change of Name Certificate Verification when conducting a face to face interview SA ING DIRECT has developed a separate Identification Form to be used if the security property is located in SA (Appendix A2). Note: The Identification Forms in Appendix A2 can only be used if the customer is in Australia. If the customer is outside Australia, the verification of the customer s identity must be conducted by an Australian Consular Officer. To correctly complete the form, follow the steps below: 1. Record details of the person being identified (including all of the details in above) 2. Collect the required identification documents (originals only) and make a copy of them 3. Record the identification documents provided. Verify the customer against the required identification documents produced, including the customer's name and customer s residential address or date of birth. 4. Sign the form, including the confirmation that you conducted a face to face verification in your customer interview. 5. Provide a copy of the customer's original identification documents and the completed Identification Form to ING DIRECT. Please note: Brokers cannot identify themselves, their spouse, partner or a dependent. If the security property is in SA, the documents that can be used to verify the identity of a customer are described in the list below. You must sight and copy either: 1. The customer should produce CATEGORY 1 documents, if these have been issued to the customer; 2. If the customer does not have the CATEGORY 1 documents, they can produce CATEGORY 2, 3 or 4 documents. 3. The customer should only produce CATEGORY 5 documents, if they are a foreign national and cannot produce the identification documents in CATEGORIES 1, 2, 3 or 4. If any of the required Identification documents are not in English, they must be accompanied by an English translation. Identification documents required for loan applications that contain South Australian properties. Page 8 of 15

9 Category Minimum Document Requirements For persons who are Australian citizens or residents: Category 1 Category 2 Category 3 Australian passport / foreign passport with an Australian resident visa label; and Australian driver s licence / proof of age card. Australian passport / foreign passport with Australian resident visa label; and birth certificate / citizenship certificate / descendent certificate; and Medicare card / Centrelink card / Department of Veterans Affairs card. Australian driver s licence / proof of age card; and birth certificate / citizenship certificate / descendent certificate; and Medicare card / Centrelink card / Department of Veterans Affairs card. Category 4 Use either option a) or option b) Option a): 1. Identifier Declaration; and 2. birth certificate / citizenship certificate / descendent certificate; and 3. Medicare card, Centrelink card / Department of Veterans Affairs. Option b): 1. Identifier Declaration by a specific class of Declarant; and 2. Medicare card / Centrelink card / Department of Veterans Affairs card. For persons who are not Australian citizens or residents: Category 5 Use either option a) or option b) Option a): 1. foreign passport; and 2. another form of government issued photographic identity document. Option b): 1. foreign passport; and 2. birth certificate; and 3. another form of government issued identity document. Note: Where necessary, a change of name certificate or marriage certificate should also be provided Verification when unable to conduct a face to face interview all States and Territories except for WA and SA If the security property is located in a state other than WA or SA, ING DIRECT s Verifying your Identity Form see (Appendix B) can be used by brokers to satisfy the verification of customer s identity if they are unable to meet with the customer face to face. Please note every effort should be made to conduct a face to face interview. This form should also be used if the applicant is also the broker or spouse, partner or dependent of the broker. To correctly complete the form, the customer will need to follow the steps below: 1. Collect the required identification documents (originals only) as described in the table located in and make copies of them 2. Take the originals and copies of these documents to a certifier as described in Step 3 of the form 3. Request the certifier to complete Step 4 of the form and certify these documents as per instructions in Step 4, Section B 4. Provide Broker with completed form and original certified identification documents 5. Broker to forward completed form and original certified identification documents (noting the deal number) to SSU for verification Verification for WA or SA when unable to conduct a face to face interview When the security property is located in WA or SA, the WA Registrar and Commissioner of Titles (Landgate) and SA Registrar- General s office require a visual (face to face) verification of the customer and anyone signing a mortgage on behalf of the customer. Should you be unable to verify the customer face to face, please contact your relevant ING Direct Business Development Manager or Relationship Manager for further guidance. Page 9 of 15

10 3.1.2 Companies Identification For the purposes of identification under the AML/CTF Act, a customer s application for a loan if applying in the capacity of a proprietary or private domestic company must include the following information: Full name of the company as registered by ASIC Full Address of the company s registered office Full Address of the company s principal place of business (if any) ACN Whether the company is registered by ASIC as public or proprietary For proprietary company s, the full name of each Director of the company* For proprietary or private companies, the full name of each beneficial owner of the company (any individual owning 25% or more of the issued capital of the company through one or more shareholdings). This is not required for a proprietary company that is licensed and subject to the regulatory oversight of a Commonwealth, State or Territory statutory regulator in relation to its activities as a company. For proprietary or private companies, the full address of each beneficial owner of the company (any individual owning 25% or more of the issued capital of the company through one or more shareholdings) This is not required for a proprietary company that is licensed and subject to the regulatory oversight of a Commonwealth, State or Territory statutory regulator in relation to its activities as a company. (Additional information will be collected as part of credit assessment procedures however the information above is mandatory for every application for a domestic company) Verification ING DIRECT will verify the required information about the company. However, it is the broker s responsibility to ensure all individual Director s, guarantors and authorised signatories who will have access to the loan are identified according to the procedure described in paragraph above for verification of individuals Trusts Identification For the purposes of customer identification of customers who wish to apply for a loan in their capacity as a Trust the following information must be collected at a minimum: Full name of the trust Full business name (if any) of the trustee in respect of the trust Type of trust Country in which the trust was established For trusts with individual trustees: See the requirements of individuals in paragraph above For trusts with company trustees: See the requirements for companies in paragraph above1 For trusts with individual trustee(s) and company trustee(s): The identification information for individuals and trustees in paragraphs and Above must be collected. Full name and address of each trustee in respect of the trust Full name of each beneficiary in respect of the trust (or if the terms of the trust identify the beneficiaries by reference to membership of a class - details of the class). The last 2 details do not need to be collected in relation to a trust that is: a managed investment scheme registered by ASIC; a managed investment scheme that is not registered by ASIC and that only has wholesale clients and does not make small scale offerings to which section 1012E of the Corporations Act applies; a government superannuation fund established by legislation; Page 10 of 15

11 a trust registered and subject to the regulatory oversight of a Commonwealth statutory regulator in relation to its activities as a trust. (Additional information will be collected as part of credit assessment procedures however the information above is mandatory for every application.) Verification ING DIRECT will verify the required information about the trust. However, it is the broker s responsibility to ensure all individual Trustees, guarantors and authorised signatories who have access to the loan are identified according to the procedures described in paragraphs above for verification of individuals. It is also the responsibility of the broker to obtain from the customer the original or a certified copy of the Trust Deed and make and provide a copy of that document to ING DIRECT s solicitors. This information should be provided to ING DIRECT by completing the Company and Trust Appendix form and forwarded with the Application. 3.2 Broker assesses product and jurisdiction risk ING DIRECT has assisted in the development of the Mortgage and Finance Industry (MFAA) AML/CTF training and accreditation package. One of the key tasks within this accreditation process is developing an understanding of the risk-based approach. The risk-based approach is a principle adopted in the legislation that permits a Reporting Entity to tailor their procedures based on the risk introduced by different: customer types; products; channels of delivery; and jurisdictions (eg of the customer, product, service, reporting entity or transactions) In order to assess the risk of the customer for the purposes of identification, you should consider two of the four factors above, product and jurisdiction. For the purposes of introducing a home loan customer to ING DIRECT, the broker only needs to consider product and jurisdiction risk. Upon receipt of the application, ING DIRECT will assess the customer risk and determine if additional customer due diligence is required Product Risk As described in the MFAA training package, the following table outlines the product risk associated with different product types in the mortgage lending industry. Should the customer be applying for any product in the standard risk category, apply the standard customer identification procedure. At this stage, ING DIRECT does not offer products that are higher risk. Standard Risk Standard Variable Rate Residential Mortgage Equity Release Mortgage Standard Fixed Rate Residential Mortgage Standard Capped/Floored/Belted Residential Mortgage Equity Finance / Shared Appreciation Mortgage Residential Mortgage with tied credit card facility Novated lease (vehicle) Bank Guarantee Business Loan Construction Loan Offset Residential Mortgage Chattel mortgage (continues overpage) Higher Risk Letter of Credit Pre-shipment finance Page 11 of 15

12 Standard Risk Higher Risk Hire Purchase Novated lease (property) Partnership commercial loan Reverse Novation Commercial Overdraft Lo-doc Residential Mortgage* Commercial Line of Credit Jurisdiction Risk The following factors should be considered in determining if the customer presents a higher than normal jurisdictional risk: Customer is not located in Australia Asset purchased with the loan is not located in Australia In the event a factor above is evident during the risk assessment, a higher standard of identification and verification is required. Refer to Section 3.4 below for enhanced customer verification requirements. 3.3 Conduct Enhanced Identification and Verification In the event the customer poses a higher than normal risk or additional information is required to satisfy know your customer reporting obligations, additional due diligence is required Broker assesses customer risk as higher than standard This would occur if either the product or jurisdiction factors described are applicable to the loan. a) If the customer is not located in Australia, perform the following: Determine the customer s reason for wanting the product Record response on application (or attach separate paperwork) Collect the country of residence Collect additional know your customer information or request additional verification evidence to confirm information provided (see below) refer also to paragraphs and if the security property is located in WA or SA. b) If the customer wishes to purchase assets not located in Australia: Determine the type of asset being purchased Determine the country of purchase Record response on application Additional know your customer information may include (depending on the customer type): any other name the customer is known by; the customer s country of citizenship; the customer s country of residence; the customer s occupation or business activities; the nature of the customer s business with ING DIRECT including - the purpose of specific transactions; or the expected nature and level of transaction behaviour; the income or assets available to the customer; the customer s source of funds including the origin of funds; the customer s financial position; Page 12 of 15

13 the beneficial ownership of the funds used by the customer with respect to products held; the beneficiaries of the transactions being facilitated by the reporting entity on behalf of the customer including the destination of funds; the full business name (if any) of the business as registered under any State or Territory business names legislation; the name of any individuals involved in the business; collection of identification information of individuals behind the business; the nature of the business activities conducted; the name and address of any beneficial owner (eg shareholder or beneficiary); the date of incorporation or registration of the business. Additional verification may include additional documents or data to verify the information provided by the customer ING DIRECT assesses customer risk as higher than standard ING DIRECT may instruct you to collect additional information from the customer. These additional requirements will become general conditions required before the loan can proceed to full approval. The following list includes examples of areas that ING DIRECT may request further information on: Additional documentation to verify information about individuals or the borrowing entity in the event of a company or trust borrower Responses to various questions to ascertain areas such as the source of funds, reason for borrowing etc Additional information surrounding customers who are not residents of Australia Customer name matches on a Politically Exposed Person s list and enhanced due diligence is required This list in not exhaustive however serves to provide examples of information that may be required. 3.5 Submit loan application, Identification Form and copies of identification ING DIRECT will continue to accept applications as per the current process. ING DIRECT will also require copies of all identification documents before the loan can proceed. It is also important the Identification Form, Verifying your Identity Form and/or the Company & Trust Appendix are correctly completed and signed. Your broker number must be provided on the Forms. Verifying your Identity Form must be submitted via the SSU and include your Broker number and the deal number. 4 Training 4.1 Initial ING DIRECT is a Reporting Entity and is responsible for ensuring all our employees and agents are AML/CTF trained and compliant. ING DIRECT is using the Mortgage & Finance Association of Australia (MFAA) AML/CTF compliance training program as the training vehicle for ING DIRECT s broker training. ING DIRECT has also recently endorsed the Finance Brokers Association of Australia (FBAA) training package. Either of these industry association training packages will meet the training requirements for brokers acting for ING DIRECT MFAA Training Brokers must sit the course, complete the online assessment and obtain a 90% pass mark for each of the five topics presented. Once Brokers have achieved a pass grade, the system will prompt them to print out their online course certificate. The Broker must send ING DIRECT a copy of the certificate via or fax: intermediary.services@ingdirect.com.au, or Fax: (02) The MFAA has also recently prepared a brochure that outlines their AML elearning accreditation program and assessment, for Brokers. Refer to the MFAA website for further information at Page 13 of 15

14 4.1.2 FBAA Training Brokers who complete the FBAA training module will need to provide ING DIRECT their course completion certificate. Brokers must complete the modules 101 and 102 in order to satisfactorily meet ING DIRECT s obligations. The Broker must send ING DIRECT a copy of the certificate via or fax: intermediary.services@ingdirect.com.au, or Fax: (02) New Brokers As at 12th December 2007, no new broker will be accredited with ING DIRECT, unless the AML/CTF training has been completed. All existing brokers are encouraged to complete this training as soon as possible. 4.2 Frequency of training It is important to keep your knowledge of AML/CTF up to date and current. Therefore ING DIRECT will require all Accredited Introducers to complete the training on an ongoing basis. The frequency will be communicated to you once determined by ING DIRECT. 4.3 Screening ING DIRECT has an obligation to perform due diligence on all third parties who assist with undertaking their obligations under the AML/CTF Act. For this reason, ING DIRECT requires all accredited introducers to be members of a professional association to ensure this screening is performed. Any introducer who is accredited via an aggregator must be appropriately screened by that aggregator. Screening should comply with the requirements of Australian Standard 4811 Employment Screening, you should advise ING DIRECT if you do not comply with this standard. You must keep records of screening undertaken, and make these available to ING DIRECT upon request. 5 Record Keeping The AML/CTF Act outlines record-keeping requirements for records relating to identification procedures. All records collected by brokers from and on behalf of customers on and after 12th December 2007 must be sent to ING DIRECT. This includes every document collected for the purpose of identifying and verifying the customer and all other required documents to approve the loan (including but not limited to those specified in Section 3). ING DIRECT will hold all records and we do not require the brokers to retain these records under the AML/CTF Act. Records relating to identification procedures include all of the following: procedures regarding how identification is carried out the copies of documents made as specified in Section 3 and other documents obtained from the customer including any further information or documents requested by ING DIRECT results of electronic verification any other information obtained during the identification procedure Record-keeping requirements extend to all customers who are identified, even if they do not proceed with taking up the designated service or product. ING DIRECT reserves the right to request further copies of documents from brokers where the copies received are not clear and/or not completed. Length of time to retain records: We are required to retain identification records for a period of seven years commencing from the time we cease to have a relationship with the customer (ie seven years after the account is closed.) 6 Suspicious Matter Reporting As our agents, brokers are in some cases best equipped to identify suspicious matters on behalf of ING DIRECT. ING DIRECT has an obligation to report certain suspicious matters to AUSTRAC within three days of a suspicion being formed or within 24 hours if the suspicion relates to the financing of terrorism. Suspicious matters must be reported even if the transaction or account does not proceed. Matters that AUSTRAC requires us to report include suspicions that: Page 14 of 15

15 the customer (or their agent) is not who they claim to be information provided may be relevant to an investigation or prosecution of a person for: (a) evasion or attempted evasion of tax (whether Commonwealth, State or Territory) (b) an offence against a State, Territory or Commonwealth Law (c) a money laundering offence; and/or (d) a financing of terrorism offence. the person is or may be attempting to disguise the proceeds of crime the person is or may be attempting to finance terrorist activities the person is or may be attempting to launder money. If you have a suspicion about a customer, you must escalate it immediately to the ING DIRECT Financial Crimes Team financial. crimes@ingdirect.com.au Please note, it is an offence for ING DIRECT to disclose the outcome of any investigation into a suspicious matter including whether or not the suspicious matter was reported to AUSTRAC. 6.1 Guidelines to trigger suspicions Suspicious activity can come in many forms, below are some examples to help you identify suspicious activity. The list is not exhaustive but aims to serve as a guide. An individual with discrepancies between their identification documentation; An individual who presents seemingly false identification; Any case when there is no obvious reason why a person is using the Bank s services; Any use of false names; An individual with a variety of similar, but different, addresses; An individual who requests to be anonymous and makes unusual requests or wishes to disguise their purpose for requesting the account A business with account turnover or large transactions inconsistent with the size of their business; and Restructuring large transactions into smaller transactions to avoid having the transactions reported to AUSTRAC. 6.2 Tipping off Where a suspicious matter comes to your attention you have an obligation to report this to ING DIRECT immediately. However you may not, in any circumstances inform anyone else (including the customer or their agent) that the matter has been reported to ING DIRECT. Severe penalties apply for persons found guilty of tipping off; these penalties include imprisonment for two years. 7 Where do I go to get clarification on an AML/CTF question? Your first point of contact is the Introducer Website. Please check for updates. You can also contact your Business Development Manager or Relationship Manager. For accreditation related matters, please contact Intermediary Services by intermediary.services@ingdirect.com.au References The Mortgage & Finance Association of Australia (MFAA) Search for AML to go to the AML link The Australian Transaction Reports & Analysis Centre (AUSTRAC) Attorney General s Department Page 15 of 15

16 Identification Form How to complete this form Step 1 Record details of the person being identified Step 2 Collect the required identification documents (originals only) Step 3 Record the identification documents provided and verify that the person s details match the identification documents Step 4 Sign the form Step 5 Provide a copy of the identification documents and the completed Identification Form to ING DIRECT Step 1 Applicant Details Mr Mrs Ms Miss Other (please specify) Surname First name Middle name Date of birth (DD/MM/YYYY) / / Residential Address Unit number Street number Street name Step 2 Collect the required identification documents Choose 2 documents from the lists below. At least 1 must be from List A. The documents must verify the following details as provided in Step 1: - Applicant s full name; and - Residential Address or Date of Birth List A Australian Drivers Licence (must be current, show current residential address and photograph) Birth Certificate or Birth Extract (issued by a State or Territory in Australia) Proof of Age Card / NSW Photo Card (must be current and show date of birth and photograph) An Australian Passport (either a current passport or a passport that expired within the last 2 years) International Passport (current, containing a photograph and a signature and accompanied by a translation from a Professional Translator accredited by the National Accreditation Authority for Translators and Interpreters if not in English) A Citizenship Certificate (issued by the Commonwealth of Australia) List B Pension Card (must be current and issued by Centrelink entitling financial benefits) Australian Tax Office Tax Assessment Notice (issued in the last 12 months and shows current residential address) A water rates or council rates notice (issued by a local government body or utilities provider within the last 3 months showing current residential address) A landline telephone, gas or electricity notice (issued by a utilities provider within the last 3 months and shows current residential address) A bank statement (issued by an Australian bank in the last 12 months. Please note printouts of online statements are not accepted) A government financial benefits notice; eg Centrelink (issued in the last 12 months and shows current residential address) Page 1 of 2 INGD IM020 02/14 ING DIRECT is a division of ING Bank (Australia) Limited ABN AFSL and Australian Credit Licence

17 Step 3 Verification Information Record details of each identification document viewed (COPIES OF ALL DOCUMENTS MUST BE PROVIDED TO ING DIRECT) LIST A DOCUMENT Document Type Name verified? Yes No Document Number Date of Birth verified? Yes No Document Issue Date Residential Address verified? Yes No Document Expiry Date Photograph verified? Yes No LIST A OR LIST B DOCUMENT Document Type Name verified? Yes No Document Number Date of Birth verified? Yes No Document Issue Date Residential Address verified? Yes No Document Expiry Date Photograph verified? Yes No Step 4 Summary Has verification been achieved? Yes No Is there a need to file a Suspicious Matter Report? Yes No Date Identification took place (DD/MM/YYYY) / / By signing this form I confirm that I have interviewed the above mentioned Applicant Face to Face and sighted the original identification documents outlined above. Signature of Introducer / Broker / ING DIRECT Employee Name of Introducer / Broker / ING DIRECT Employee Broker Number Date (DD/MM/YYYY) / / Note: It is an offence under the Anti-Money Laundering / Counter-Terrorism Financing Act 2006 to provide a false or misleading statement, produce a false or misleading document, to receive an ING DIRECT product in a false name or to fail to disclose any other name or names you are commonly known by. Page 2 of 2 INGD IM020 02/14 ING DIRECT is a division of ING Bank (Australia) Limited ABN AFSL and Australian Credit Licence

18 Identification form (Landgate - WA Mortgage) How to complete this form This form should only be used to identify an applicant in Australia. Where the applicant is outside Australia, the verification of identification must be conducted by an Australian Consular Officer. Step 1 Record details of the person being identified Step 2 Ensure that the identification documents are current and collect the required identification documents (original only) Step 3 Record the identification documents provided and verify that the person s details match the identification documents Step 4 Sign the form Step 5 Provide a copy of the identification documents and the completed Identification Form to ING DIRECT Step 1 Applicant Details Mr Mrs Ms Miss Other (please specify) Surname First name Middle name Date of birth (DD/MM/YYYY) / / Residential Address Unit number Street number Street name Step 2 Collect the required identification documents You should produce CATEGORY 1 documents, if these have been issued to you. If you do not have the CATEGORY 1 documents, you may produce CATEGORY 2 or 3 documents. You should only produce CATEGORY 4 documents, if you are a foreign national and cannot produce the identification documents in CATEGORIES 1,2 or 3. If any of the Identification documents are not in English, they must be accompanied by an English translation. Category 1 Category 2 Category 3 Category 4 Australian Passport Australian Passport Australian Drivers Licence; Australian Proof of Age Card with photo. Foreign Passport with Australian Visa; Australian Drivers Licence; Australian Proof of Age Card with photo. Birth Certificate; Citizenship Certificate Australian Drivers Licence; Australian Proof of Age Card with photo. Birth Certificate; Citizenship Certificate A Rates Notice issued in the last 12 months. Medicare card; Centrelink card; Department of Verteran Affairs (DVA) card. Medicare card; Centrelink card; Department of Verteran Affairs (DVA) card. Australian Drivers Licence; Foreign Drivers Licence. (if required) Change of Name * Marriage Certificate Change of Name Certificate. (if required) Change of Name * Marriage Certificate Change of Name Certificate. (if required) Change of Name * Marriage Certificate Change of Name Certificate. (if required) Change of Name * Marriage Certificate Change of Name Certificate. Page 1 of 2 INGD IM020WA 02/14 ING DIRECT is a division of ING Bank (Australia) Limited ABN AFSL and Australian Credit Licence

19 Step 3 Verification Information Record details of each identification document viewed (COPIES OF ALL DOCUMENTS MUST BE PROVIDED TO ING DIRECT) CATEGORY 1, 2, 3 or 4 DOCUMENT Document Type Name verified? Yes No Document Number Date of Birth verified? Yes No Document Issue Date Residential Address verified? Yes No Document Expiry Date Photograph verified? Yes No CATEGORY 1, 2, 3 or 4 DOCUMENT Document Type Name verified? Yes No Document Number Date of Birth verified? Yes No Document Issue Date Residential Address verified? Yes No Document Expiry Date Photograph verified? Yes No CATEGORY 1, 2, 3 or 4 DOCUMENT (if required) Document Type Name verified? Yes No Document Number Date of Birth verified? Yes No Document Issue Date Residential Address verified? Yes No Document Expiry Date Photograph verified? Yes No CATEGORY 1, 2, 3 or 4 DOCUMENT (if required) Document Type Name verified? Yes No Document Number Date of Birth verified? Yes No Document Issue Date Residential Address verified? Yes No Document Expiry Date Photograph verified? Yes No Step 4 Summary Has verification been achieved? Yes No Is there a need to file a Suspicious Matter Report? Yes No Date Identification took place (DD/MM/YYYY) / / By signing this form I confirm that I have interviewed the above mentioned Applicant Face to Face and sighted the original identification documents outlined above. Signature of Introducer / Broker / ING DIRECT Employee Name of Introducer / Broker / ING DIRECT Employee Broker Number Date (DD/MM/YYYY) / / Note: It is an offence under the Anti-Money Laundering / Counter-Terrorism Financing Act 2006 to provide a false or misleading statement, produce a false or misleading document, to receive an ING DIRECT product in a false name or to fail to disclose any other name or names you are commonly known by. Page 2 of 2 INGD IM020WA 02/14 ING DIRECT is a division of ING Bank (Australia) Limited ABN AFSL and Australian Credit Licence

20 Identification form (South Australia - SA Mortgage) How to complete this form This form should only be used to identify an applicant in Australia. Where the applicant is outside Australia, the verification of identification must be conducted by an Australian Consular Officer. Step 1 Record details of the person being identified Step 2 Ensure that the identification documents are current and collect the required identification documents (original only) Step 3 Record the identification documents provided and verify that the person s details match the identification documents Step 4 Sign the form Step 5 Provide a copy of the identification documents and the completed Identification Form to ING DIRECT Step 1 Applicant Details Mr Mrs Ms Miss Other (please specify) Surname First name Middle name Date of birth (DD/MM/YYYY) / / Residential Address Unit number Street number Street name Step 2 Collect the required identification documents You should produce CATEGORY 1 documents, if these have been issued to you. If you do not have the CATEGORY 1 documents, you may produce CATEGORY 2 or 3 documents. You should only produce CATEGORY 4 documents, if you are a foreign national and cannot produce the identification documents in CATEGORIES 1,2 or 3. If any of the Identification documents are not in English, they must be accompanied by an English translation. Category 1 Category 2 Category 3 Category 4 Australian Passport Foreign passport including an Australian resident visa label Australian Passport Foreign passport including an Australian resident visa label Australian Drivers Licence; Proof of Age Card Foreign passport Australian driver s licence Australian Proof of Age Card Full Birth Certificate Citizenship Certificate Descent Certificate Full Birth Certificate Citizenship Certificate Descent Certificate Another form of government issued photographic identity; OR Full Birth Certificate Another form of government issued identity Medicare Card; Centrelink card; Department of Veterans Affairs card Medicare Card; Centrelink card; Department of Veterans Affairs card (if required) Change of Name * Marriage Certificate Change of Name Certificate. (if required) Change of Name * Marriage Certificate Change of Name Certificate. (if required) Change of Name * Marriage Certificate Change of Name Certificate. (if required) Change of Name * Marriage Certificate Change of Name Certificate. Page 1 of 2 INGD IM020SA 11/13 ING DIRECT is a division of ING Bank (Australia) Limited ABN AFSL and Australian Credit Licence

21 Step 3 Verification Information Record details of each identification document viewed (COPIES OF ALL DOCUMENTS MUST BE PROVIDED TO ING DIRECT) CATEGORY 1, 2, 3 or 4 DOCUMENT Document Type Name verified? Yes No Document Number Date of Birth verified? Yes No Document Issue Date Residential Address verified? Yes No Document Expiry Date Photograph verified? Yes No CATEGORY 1, 2, 3 or 4 DOCUMENT Document Type Name verified? Yes No Document Number Date of Birth verified? Yes No Document Issue Date Residential Address verified? Yes No Document Expiry Date Photograph verified? Yes No CATEGORY 1, 2, 3 or 4 DOCUMENT (if required) Document Type Name verified? Yes No Document Number Date of Birth verified? Yes No Document Issue Date Residential Address verified? Yes No Document Expiry Date Photograph verified? Yes No CATEGORY 1, 2, 3 or 4 DOCUMENT (if required) Document Type Name verified? Yes No Document Number Date of Birth verified? Yes No Document Issue Date Residential Address verified? Yes No Document Expiry Date Photograph verified? Yes No Step 4 Summary Has verification been achieved? Yes No Is there a need to file a Suspicious Matter Report? Yes No Date Identification took place (DD/MM/YYYY) / / By signing this form I confirm that I have interviewed the above mentioned Applicant Face to Face and sighted the original identification documents outlined above. Signature of Introducer / Broker / ING DIRECT Employee Name of Introducer / Broker / ING DIRECT Employee Broker Number Date (DD/MM/YYYY) / / Note: It is an offence under the Anti-Money Laundering / Counter-Terrorism Financing Act 2006 to provide a false or misleading statement, produce a false or misleading document, to receive an ING DIRECT product in a false name or to fail to disclose any other name or names you are commonly known by. Page 2 of 2 INGD IM020SA 11/13 ING DIRECT is a division of ING Bank (Australia) Limited ABN AFSL and Australian Credit Licence