AML Requirements

Heritage Identification Requirements

Identification Requirements (PDF)

Non face-to-face interviews

Where the broker has not been able to interview the applicant in person, the broker's signature is required in the 'Broker Disclosure' section on the Home Loan Application Form.

There will be times when it is impractical or inconvenient for the customer to attend a face-to-face interview for a loan application.

Applications may be accepted from new customers without a face-to-face interview & will require the following AML identification process:

  • All new customer applicants or those not AML identified, are to be identified via InfoTrack or at a Heritage branch.

Reporting Suspicious Activities to Heritage

  • Brokers and Heritage have a shared obligation in regard to AML/CTF obligations.  Brokers are responsible for collecting identification information and reporting suspicious matters to Heritage.
  • If a broker is suspicious that a customer is not who they claim to be this is to be reported to Heritage.
  • If a broker suspects that an activity or transaction is suspicious this is also to be reported to Heritage.
  • A suspicious matter is to be reported to Heritage's Financial Crimes Unit:
  • When reporting a suspicious matter, please collate as much information on the customer as possible.
  • Common indicators of suspicious transaction:
    • Activities with little or no business sense
    • Reluctance to provide identification or explanation
    • Trying to use aliases or a variety of addresses
    • Nervous or agitated behaviour
    • Unexplained money

Record Keeping Requirements

  • Under the AML/CTF Act, Heritage is required to retain a record of customer identification, account and transaction details for a period of seven years after the relationship with the customer ends.
  • Under the legislation Brokers may be requested to provide copies of documentation obtained from the customer, that has not been provided to Heritage.  As such, Brokers may also need to keep a records of identification of the customer for a period of seven years after the Broker's relationship with the customer ceases.
  • Heritage requires brokers to forward all copies of identification documentation to Heritage.

Training Requirements

  • It is the policy of Heritage to not accept loans by Brokers who have not completed the MFAA or FBAA training.
  • Heritage will follow-up and investigate the information provided and submit the suspicious matter to AUSTRAC.