The FAAA also flags inconsistencies between AUSTRAC’s guidance and product provider identification requirements.
The association has argued that financial and elder abuse should be taken into account when considering the use of non-standard identification documents.
In its submission to an AUSTRAC consultation on assisting customers who don’t have standard forms of identification, the association said the ramifications of “undue influence” and financial abuse are serious considerations for financial advisers.
“The proposed guidance suggests that a referee statement should be witnessed by an independent person, particularly if there is the potential for undue influence on the customer,” the submission said.
“Undue influence can be a symptom of financial abuse and often occurs in elder abuse situations. Financial advisers are deeply concerned for the victims of financial abuse and are uniquely positioned to detect signs of financial abuse due to their close relationships with clients and their families.”
Noting that issues surrounding financial and elder abuse often fall within the realm of domestic and family violence, the FAAA backed the consideration of financial and elder abuse “as an exceptional case where non-standard identification may be accepted”.