A quick recap on reforms affecting reporting entities The Amended AML/CTF Act removed the concept of "designated business groups" and replaced this with "reporting group". The concept of "reporting group" means that, if relevant control exists, a "reporting group" will be automatically formed. There is also the ability to elect to form a reporting group. However, this does not allow an automatic reporting group to be displaced. Every reporting group, whether automatic or by election, must have a lead entity. This means that wherever there is an entity providing a designated service in a business group, there will also be a lead entity regulated under the Amended AML/CTF Act. Importantly, the lead entity does not itself need to provide designated services.
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