What is AUSTRACs policy in relation to pre-commencement customers of a managed investment scheme?
A. Even though managed investment schemes are captured by the AML/CTF Act from 31 January 2008, any new customers to whom interests in a managed investment scheme were issued by a company issuer between 12 December 2007 and 31 January 2008 would not be pre-commencement customers (as defined in section 28 of the AML/CTF Act). However, it is AUSTRAC policy to treat such customers as pre-commencement customers. To give effect to that policy, AUSTRAC has issued a declaration under section 248 of the AML/CTF Act.
