Whistleblower, Modern Slavery, AML/CTF, ABAC & AFSLs with Kathryn Morgan

Whistleblower, Modern Slavery, AML/CTF, ABAC & AFSLs with Kathryn Morgan

Episode 21 - Shownotes

In this episode of YS Up Governance and Boards Podcast, 3YS Owls Governance Consultants, Ainslie Cunningham and Deb Anderson interview Kathryn Morgan. Kathryn is a Senior Associate (Financial Services) at McCullough Robertson Lawyers. We talk to Kathryn about the enhanced whistleblower protections, modern slavery, AML/CTF, ABAC and other challenges for financial services providers, mining and engineering firms, professional services firms and educational institutions.

It [Modern Slavery Act) obviously came into effect in 2019, so it's not necessarily new law now, but the first set of reporting requirements are now coming up. They have all been pushed back by three months due to COVID like most regulators…

I think it's important to note that, It's not saying that you have to look at your supply chains and be absolutely certain that there is no modern slavery in your supply chains because quite frankly, that is impossible. Anyone that has a smartphone has benefited in some way, shape, or form, from modern slavery, unfortunately. But what it is about doing is, trying to create as much transparency as possible, given the nature of your business, given the types of goods and services that you're providing, and where possible, trying to remove any obvious instances of modern slavery. So, it really needs to be looked at on a case by case basis.

So if, for example, you're manufacturing technology equipment and you're getting a lot of raw materials from a country that's a vulnerable jurisdiction, the kinds of checks, and balances and the due diligence that you're going to put in place for those suppliers is going to be very different for a small accounting business that employs five people and might occasionally buy some merchandise from China. Both require due diligence, and both would require checks. And obviously, the latter businesses are unlikely to be captured by the mandatory criteria and having to report, but it's the framework that any business can and probably should implement.

Kathryn Morgan

Summary of episode
About Kathryn Morgan

Kathryn is a financial services regulatory lawyer, specialising in white collar crime regulation and compliance. Kathryn acts for clients from a variety of industry sectors, including mining and engineering firms, professional services firms, educational institutions and financial services providers. She advises on matters regarding anti-money laundering and counter terrorism, (AML/CTF), international sanctions, foreign bribery, modern slavery, whistleblower protection laws and other white-collar crime issues.

Kathryn brings both in-house and private practice experience, having previously worked as an in-house legal counsel for the wealth management business unit at the Commonwealth Bank of Australia. Kathryn's experience includes advising various clients on their obligations as existing or potential reporting entities under the AML/CTF Act and advising various listed and unlisted, Australian and multinational entities in relation to addressing a range of integrity risks applicable to their operations, including UNSC sanctions regimes.

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