7 August 2019
We acknowledge The Australian Securities and Investments Commission’s (ASIC) intention to provide ‘high level’ guidance, and to rely on the ordinary meaning of ‘significant detriment’. However, for the efficient implementation of this measure, maximum clarity around the meaning of this term is desirable.
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The Australian Banking Association welcomes the opportunity to comment on the Consultation Paper – 2026 Reforms to the AML/CTF Act.
The ABA appreciates the opportunity to contribute to the RBA’s Review of Merchant Payment Costs and Surcharging (Proposals Paper).
The ABA thanks ASIC for the opportunity to comment on its discussion paper on the dynamics between public and private markets.