6 December 2021
The ABA strongly recommends the Bill be amended to apply the OP Code more clearly and narrowly to the digital platforms on which the Inquiry focussed and the banking sector be expressly excluded from the definition of OP Organisations. The annexure provides detail in support of the recommendation. Additionally, in part two of the annexure we make suggestions in relation to the OP Code development, the OP Code scope and drafting matters relating to the Bill.
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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.