Tony is known by his clients for his ability to interpret and provide practical applications of anti-money laundering and counter terrorism financing laws, laws regulating the provision of credit to consumers, and rules governing the offer of banking products such as deposit accounts and foreign exchange services. Where relevant, this includes the design of methods and processes for ensuring the creation and perfection of effective security interests for the purposes of personal property securities laws. Many clients call on Tony to advise on issues and transactions relating to participation in payment systems.

Career highlights

• On many occasions, carrying out an assignment for a client to scope non-compliance with AML/CTF laws, work with risk consultants to redesign a remediation program, and engage with AUSTRAC in relation to the remediation.
• Working with a client through the 17-year life of a co-branded credit card program from negotiation and creation through to unwinding of the relationship.
• Drafting the governance documents for a real-time "any account to any account" cross border payments system for customers of participating banks.
• Completing an unfair contract terms review and revision of all consumer and small business contracts for a large ADI.
• Acting as external counsel on the design and adoption of a responsible lending program of a 'Big 4' bank.
• Working as external counsel to redesign all of the processes and systems of the business bank of a 'Big 4' bank to address the requirements of the Personal Property Securities Act.
• Supporting a client in proceedings for breach alleged by ASIC in relation to the unfair contract terms regime.
• Assisting from the ground up with all legal aspects of the establishment of a highly successful non-bank lender offering regulated consumer loans.

• A new dawn: AML/CTF reforms finally see the light of day
  

  The Australian Parliament has passed legislation introducing substantial reforms to the AML/CTF regulatory regime. We consider the reform, and the changes that Parliament made to the Bill before it was passed.

• AML/CTF reforms - AUSTRAC releases draft rules for public consultation
  

  On 11 December 2024, AUSTRAC released draft rules for public consultation, following the recent passing of the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Amendment Act 2024. Discover the insights.

• ASIC moves to update crypto rules - Key changes for 2025
  

  On 4 December, ASIC commenced consultation on proposed changes to its existing guidance on digital assets. We discuss the proposed changes.

• The AML/CTF challenge for gatekeepers
  

  The Australian AML/CTF regime has been extended to include gatekeeper professionals (such as lawyers, accountants and real estate agents). This article provides practical guidance as to what these gatekeeper entities need to consider and how challenging operationalising these changes can be.

• Imminent changes to tipping off prohibitions in AML/CTF Act
  

  We explore the upcoming changes to Section 123 of AML/CTF Act promising easier information sharing to overcome current tipping off hurdles.

• AUSTRAC key guidance released on 2026 AML/CTF reforms
  

  AUSTRAC has released its key guidance on the AML/CTF reforms, providing comprehensive direction on the interpretation and practical application of the revised regime.

• New AML rules target nested services relationships
  

  Nested Services Relationships are now formally defined under the AML/CTF Act, capturing arrangements between financial institutions, remitters, and virtual asset service providers where services are provided between jurisdictions.

• AML/CTF Reforms: New 'value transfer' reporting obligations
  

  AML reforms redefine 'value transfer' services, expand reporting duties, and introduce new obligations for virtual assets and transfers.

• Changes to formation of AML/CTF reporting groups
  

  A reporting group will replace the concept of a designated business group and will be more flexible.

• AML/CTF Reform - A guide for Tranche 2 services
  

  A number of new "designated services" will now be subject to AML/CTF laws and many businesses will be regulated for the first time. Our guide explains the key requirements of the regime, common issues faced and steps you can take now.

• Reimagining Customer Due Diligence: Australia's AML/CTF Reform
  

  A landmark shift for financial crime compliance in Australia, the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 (Cth) (Act) will redefine how Australian businesses approach Customer Due Diligence (CDD).

• Money mules: what financial services organisations need to know
  

  We explore practical measures banks can focus on to detect and disrupt the use of money mules.

• AML/CTF: Navigate your compliance journey
  

  A complete overhaul of Australia’s AML/CTF regime is in train.  Changes for providers of existing designated services take effect from 31 March 2026. By 1 July 2026 tens of thousands of new entities will also be regulated for the first time.

• AML/CTF Reform - A guide for existing reporting entities
  

  Existing reporting entities will need to make important adjustments to how they manage risks and obligations. Our guide explains key changes, implications, potential challenges and what you can do now.

   

• AML/CTF: The countdown to commencement
  

  Commencement dates are fast approaching for changes to Australia's AML/CTF regime. We explore the latest updates on the changes that take effect from 31 March 2026 for existing reporting entities and from 1 July 2026 for newly regulated entities.