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Episode 156
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Practice Management and Business Skills Substantive Law
Everything You Need to Know About the AML/CTF Reforms
Law as stated: 28 October 2025
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This episode was published and is accurate as at this date.
Jeremy Moller, Senior Advisor at Norton Rose Fulbright, joins David to unpack Australia’s anti-money laundering reforms. He explains how the new Tranche 2 laws will reshape compliance for lawyers, accountants and real estate professionals and why vigilance against financial crime is everyone’s responsibility, not just banks and regulators.
Practice Management and Business Skills
Substantive Law| What area(s) of law does this episode consider? | The incoming AML/CTF reforms. |
| Why is this topic relevant? | Money laundering and terrorism financing are big challenges for Australia, with organised crime costing the country an estimated $60.1 billion every year. Now, these might sound like large scale issues best left to banks and law enforcement – but the reality is: these activities are actually often operating in broad daylight, under the radar, with the unknowing help of innocent and legitimate businesses. And unfortunately, even professional services, with all their care and caution, are finding themselves in the crosshairs of these illegal schemes. For lawyers, failing to ask the right questions about where a client’s funds are coming from, or not fully understanding who’s behind a deal, can lead to more than just reputational damage or a breach of professional obligations. These activities fund some of the most devastating crimes – like human trafficking and child exploitation – and cause untold harm across the globe. To tackle these issues, the Australian Government is making some pretty big changes. On the 29th November 2024, the Anti-Money Laundering and Counter-Terrorism Financing Amendment Bill 2024 (Cth) was passed in Parliament, marking the biggest reforms to the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) since its introduction. For many professional service industries, these reforms bring new challenges but also opportunities to step up and play a key role in preventing financial crime. |
| What legislation is considered in this episode? | Anti-Money Laundering and Counter-Terrorism Financing Amendment Bill 2024 (Cth) (Tranche 2 Reforms) Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act) |
| What are the main points? |
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| What are the practical takeaways? |
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| Show notes | AUSTRAC, Strategic analysis brief Money laundering through real estate (2025) |
DT = David Turner; JM = Jeremy Moller; TH = Taylor Harding
| 00:00:00 | DT: | Hello and welcome to Hearsay the Legal Podcast, a CPD podcast that allows Australian lawyers to earn their CPD points on the go and at a time that suits them. I’m your host, David Turner. Hearsay the Legal Podcast is proudly supported by Lext Australia. Lext’s mission is to improve user experiences in the law and legal services and Hearsay the Legal Podcast is how we’re improving the experience of CPD. In Australia, organised crime costs the country a little over $60 billion every year and at that scale and volume, it might seem like these are large scale issues that are best left to the banks and our law enforcement agencies but the reality is this; these activities, especially money laundering, which is an important part of organised crime as a business, are often happening in broad daylight under the radar with the unknowing help of innocent and legitimate businesses, including I would add law practices like yours or mine. And, unfortunately, even professional services with all their care and caution are finding themselves in the cross hairs of these organised crime money laundering schemes. For lawyers, failing to ask the right questions about where a client’s funds are coming from or not fully understanding who’s behind a deal can lead to more than just reputational damage or a breach of professional obligations. These activities fund some of the most devastating crimes – human trafficking, child exploitation, terrorism – and cause untold harm across the globe. Now, to tackle these issues, the Australian government is making some pretty big changes to the way anti-money laundering is regulated in this country. On the 29th of November, 2024, the Anti-Money Laundering and Counter-Terrorism Financing Amendment Bill 2024 (Cth) passed Commonwealth Parliament marking the biggest reforms to the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) since its introduction. For many professional service industries, including law, these reforms bring new challenges but also opportunities to step up and play a key role in preventing financial crime. Today we’re thrilled to be joined by Jeremy Moller, a Senior Advisor in Risk Advisory at Norton Rose Fulbright. Jeremy has extensive experience in compliance and regulatory frameworks and is here to help us unpack these reforms, explain what they mean for businesses, including law practices, and share practical tips on how to prepare for them coming into force. Jeremy, thank you so much for joining me today on Hearsay. |
| 00:02:20 | JM: | Brilliant. Thank you for inviting me on. |
| 00:02:21 | DT: | Now, before we get into it, tell me a little bit about how you got into doing this kind of work. |
| 00:02:25 | JM: | Yeah, quite a unique journey. So I grew up in New Zealand and actually practised first insolvency law, which you would do during the Global Financial Crisis. So that’s where I started out. After doing that for three years, I probably worked out I didn’t want to be an insolvency litigator and actually traveled for a year, made my way to London. By the time that I was there, I got an in-house compliance role and that was primarily conflicts of interest but also sanctions. So it was 2013/2014 and the Russian sanctions were commencing and we actually had a Moscow office at the firm I was at at the time. So got very involved in international sanctions, then progressed into anti-money laundering. So doing that in-house within a law firm and actually for the last six years back in Australia, advising clients on that. So it’s been a growth area. |
| 00:03:11 | DT: | It’s funny you say that. So I did detect the accent so I could tell you practised in New Zealand, as some of our listeners may know. I used to be an insolvency lawyer myself and funnily enough, one of my first ever gigs in law in my graduate program was in the compliance team at Norton Rose Fulbright doing the anti-money laundering and sanctions checks that you are describing. So it’s funny just how closely some of our roles and our careers have aligned there and it was always interesting to me – unpacking these corporate structures, I think it was quite good training for sort of corporate advisory work in the future because you really go deep into these structures, you unpack the trust relationships and you get to see beneficially who’s sitting maybe several strata up in the structure, which is kind of something we’re going to be talking about today, isn’t it? Understanding who the real beneficiaries of a transaction are. |
| 00:03:56 | JM: | And I just want to touch on that. So insolvency law is often about where you follow the money. Anti-money laundering is about where you follow the money. So that was the synergy in terms of my practice. I’d spend that time doing insolvency law going, “who needs to be paid? Where’s the money? How do we find it?” To the point then when you’re looking at anti-money laundering, as you say, looking at these complex structures and how you unpack that. So yeah, very much a synergy there. |
| 00:04:19 | DT: | Yeah, same tasks, two directions. |
| 00:04:21 | JM: | Correct. |
| 00:04:21 | DT: | Where are we going to get the money from to bring it back in? And where’s the money flowing out of to? Now, as we said at the top of the episode, this is an enormous problem in terms of its scale and volume – $60 billion in Australia, I can only imagine what the global volumes are – and so this is a global problem. How are global trends in financial crime affecting anti-money laundering practice here in Australia? |
| 00:04:41 | JM: | I think what we have to do, where we think globally, there is always the flow of the proceeds of crime between countries. So what anti-money laundering is effectively trying to do is make sure that we put the relevant controls in place to deal with that. We’re in a very dynamic geopolitical environment and what we have to appreciate is Australia’s one of the last five countries to put in place these laws for real estate, accounting and legal. So when we look at that, Australia is an attractive market to place your potentially illicit funds. So taking an example of that – real estate in Australia, real estate’s often, always likely to go up. We’ve got stable rule of law and so without these anti-money laundering controls in place, doesn’t mean anybody’s doing the wrong thing when they receive those funds but it could be unwitting, as you said earlier. So that’s the challenge we have globally. We are an attractive market for the movement of those illicit funds. |
| 00:05:33 | DT: | Yeah I hadn’t really considered that. As anti-money laundering controls become more strict elsewhere in the world, the prevalence of money laundering in Australia increases. |
| 00:05:43 | JM: | Correct. Particularly as we’re a stable economy. So if you think about it, if you needed somewhere to put your illicit funds, you would look for an economy that does have good structures in place. As we know, property’s pretty buoyant. We’re based here in Sydney, so when we look at that, we sometimes probably forget that some of those illicit funds could be actually heating up some of that property market. So that could be the case but really just thinking, we’ve got to understand this globally, it is an issue and organised crime globally utilises these types of methods. So we’ve got to make sure that we put in the appropriate controls here in Australia. |
| 00:06:16 | DT: | It’s an unusual paradox, isn’t it, that an organised crime syndicate might look for a country with strong rule of law to protect their quote unquote investment, so long as there’s a black spot around money laundering. |
| 00:06:27 | JM: | Correct but that’s if you can get the funds into a jurisdiction like ours, therefore people have greater comfort. So that’s sometimes the challenge. Ot may go through a number of countries, it may go through a number of legal structures but I think we sometimes forget that we can do this unwittingly. Now, banks, payment providers, casinos, entities like that are already regulated. So when we talk about tranche 2 and the entities that are going to be regulated, lawyers, accountants, real estate professionals, we have to appreciate if we don’t regulate those, that we’ve got a vulnerability there. TIP: Australia’s anti-money laundering and counter-terrorism financing regime is designed to detect, deter and disrupt financial crimes. The primary legislative framework consists of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act or Act), a Commonwealth piece of legislation, which operates alongside the Criminal Code Act 1995 (Cth) (Criminal Code) and the Proceeds of Crime Act 2002 (Cth) (Proceeds of Crime Act), also both Commonwealth pieces of legislation. All of these laws work together to regulate financial transactions, prosecute offences and confiscate illicit assets. Under the Criminal Code, money laundering is broadly defined in Division 400 to include dealing with both the proceeds and instruments of crime. This means that a person does not have to actively launder money to commit an offence – simply handling illicit funds or facilitating their movement can be enough. The AML/CTF Act reinforces these provisions in Part 12, making it an offence to engage in transactions that involve criminal proceeds. The Proceeds of Crime Act provides mechanisms for confiscating assets linked to criminal activity. This can be done through both civil and criminal provisions and allows authorities to seize property without a criminal conviction if they can demonstrate that the assets were obtained unlawfully. The Proceeds of Crime Act also includes unexplained wealth provisions, which is strengthened by the Crimes Legislation Amendment (Serious and Organised Crime) Act 2010 (Cth), which requires individuals suspected of possessing wealth beyond their legal income to prove its legitimacy. If they fail to do so, their assets can be confiscated. These laws also exist at the state and territory level. Australia’s AML/CTF framework primarily applies to financial institutions, superannuation providers and gambling services but historically did not apply to tranche 2 entities like lawyers, accountants and real estate agents, as Jeremy’s mentioning here. Businesses regulated under the AML/CTF framework must conduct customer due diligence, assess money laundering risks, report suspicious transactions and implement compliance programs. And AUSTRAC – the regulator responsible for enforcing AML/CTF laws – monitors these obligations and takes enforcement action against non-compliant entities. |
| 00:08:56 | DT: | Now, tell me a little bit about the goals of these reforms. As I said, they’re very significant reforms, the most significant since the Act was first introduced. You touched on just now the industries that they’re going to cover, including our own, which as I’ve heard in commentary around the Bill is long overdue along with real estate. Tell me a bit more about what the regulations are achieving. |
| 00:09:15 | JM: | Yeah, so the reference is often made to tranche 2, that’s because the laws were originally put in place for anti-money laundering in 2006. So tranche 2 was always anticipated to happen but we are now 19 years later, of course, the Bill has passed and you know it will become active in 2026 but that’s what it’s referred to as tranche 2. So currently there’s 17-18,000 regulated entities in Australia, with these additional entities that would go to over 100,000. |
| 00:09:42 | DT: | Wow. |
| 00:09:42 | JM: | So the scale of it is growing. Also, as the Act was drafted in 2006, it hasn’t had substantive amendment. We all know what commerce was like in 2006 – very different to today. So they’re trying to simplify and modernise the Act and the rules as well. I guess the idea is; make it more practical but also as I say, to actually target that illicit activity. So the idea is really actually make it more current, make it more practical, particularly with modern technology and payment systems and how we do commerce but it is quite substantive and that’s why there is a lot of commentary and interest in this because it is a huge change both for those new reporting entities but also for those existing reporting entities. |
| 00:10:22 | DT: | Yeah, well, I think about 2006, that’s pre cryptocurrency, right, which is the kind of payment system of choice of organised crime today or often is. There’s plainly a need to, well, modernise but as you say, also simplify, I suppose. The simplification of legislation can broaden its scope and reach. |
| 00:10:41 | JM: | Correct. You know, I’ll give a personal anecdote here. I was moved out to Australia 10 years ago for tranche 2. It got passed late last year, so I became an Australian citizen early last year. So when we put that in perspective, it’s been coming for a long time and I think as a consequence, it’s made the change far bigger because other countries have done it, take for example, the UK regulated lawyers 20 years ago, New Zealand did it after the Panama Papers five or six years ago. So it feels like this change is very big and that’s one of the real challenges which we’ll get onto, is how you actually practically do that but also for banks, payment providers, casinos and others, they’ll have an interest in making sure the regulations are fit for them and that’s a challenge, right? You’ve got all of these different sectors trying to comply with the same legislation. Some will be huge businesses that we know are listed on the Australian Stock Exchange, others will be one person businesses. So the regulatory impact of what we’re looking at is vast. |
| 00:11:40 | DT: | Yeah, I’d be really interested to know what that looks like for that latter category. We know the shape of the legal profession is overwhelmingly weighted towards smaller practices – practices with three or fewer principles, indeed, sole practices make up a large part of our legal practice. For lawyers in their day-to-day work after trench two comes into effect, what is going to be the biggest change to their day-to-day work? And I’m thinking especially about those smaller practices. |
| 00:12:06 | JM: | Yeah. I would actually give you some statistics first because of my work with the Law Council of Australia but also the New South Wales Law Society. So 93% of law firms in Australia are four partners or less. 89% are one partner. |
| 00:12:21 | DT: | Yep, right. That gives you an impression of just how many small businesses, single principal practices are going to be effected by this. |
| 00:12:27 | JM: | Correct and effectively micro-businesses. So looking at those types of entities – the biggest change – they understand the law quite well and they can look at the Act and rules and have a good sense of what to do with the level of training and a level of guidance, which AUSTRAC as the regulator will be assisting with the real challenges augmenting and changing your processes. So things like customer due diligence – what will often be termed ‘KYC’ – that’s what’s quite challenging for people. So for every regulated activity you provide – what’s known as a designated service – you would have to do that customer due diligence and that’s the piece that operationally is quite challenging, both based on volume and time but also complexity. We spoke earlier about complex overseas structures and things like that. Trying to find the beneficial ownership, which is required, takes time and energy. So for these smaller practices, we can get across the level of the detail, it’s the time, energy and resource that it will take. |
| 00:13:24 | DT: | Yeah. And money. |
| 00:13:25 | JM: | Correct. Time is money. Yeah. |
| 00:13:27 | DT: | And also – this is a little bit of a bugbear of mine because I think your motherland does it quite well – we talked on the show before about how we think that maybe ASIC should stop charging for company searches, which has been something that was on the roadmap I think a few years ago but it’s fallen by the wayside. In New Zealand, that information is freely available to the public. If you are a sole practice, you’re doing an engagement for $500 or something at a fixed fee and you have to get three company searches to identify the ultimate beneficial owner in a group, you’ve thrown away the better part of 20% of your fee. |
| 00:13:57 | JM: | Correct and that’s one of the reasons I’ve been involved in these committees are really passionate about supporting those small law firms and thinking about how that can impact access to justice and things like that and we have to see the ultimate cost to the individuals, the people paying for those legal services, but you’re absolutely right, fees may go up and therefore also the burden on lawyers who are already actually doing it quite tough, as we know, there’s a cost of living crisis, so we have to be really mindful of how both that cost is passed on but also the burden on lawyers. So that’s things that we are working on to try and make it easier for them. |
| 00:14:30 | DT: | Absolutely. Sorry, I got a little off topic there. Any chance I get to complain about ASIC charging for company searches, I like to take it. Now, one of the key obligations under anti-money laundering legislation, which law practices will be required to comply with is reporting suspicious activities or suspicious transactions. You know, it occurred to me that, you know, I was speaking to someone about this topic the other day in preparation for our interview and a lot of our listeners, despite being commercially experienced, wise, trusted advisors might not really know what a suspicious transaction from a money laundering perspective looks like or what the purpose of those transactions might be. So maybe before we even walk through the due diligence requirements, let’s talk about what a suspicious transaction might look like and what the people involved in it are seeking to do. |
| 00:15:14 | JM: | Yeah and it’s worth keeping in mind, it’s not always going to be your client and often won’t be and that’s an important distinction. So let’s try and look at a real estate transaction. So a lawyer is acting on the conveyancing, they’re acting for the seller of that property. We don’t know who the buyer is going to be at the start of that matter, necessarily, and there are a number of people who put in offers in relation to that property and the winning entity is an offshore entity, it’s based on the Cayman Islands, we can’t find its directors but we see some negative news about the company and links to organised crime – as a hypothetical. Right? That’s one of the challenges. So you’ve done all the due diligence on your client but actually then it’s looking at the counterparty and how that could pose risk. So you’ve seen that it’s in an offshore tax minimisation jurisdiction, you’ve seen some negative news in relation to that entity and it’s come in quite late in the transaction. You didn’t know it was going to be the buyer until very late. Those are the type of things that you’ve got to be concerned about. The other one might be you’re trying to settle the property transaction and the purchaser changes at the last moment and it says the buyer’s going to be from XYZ jurisdiction and it changes to ABC jurisdiction and ABC jurisdiction is a jurisdiction with sanctioned persons. |
| 00:16:31 | DT: | Yes. That classic sort of “purchaser or their nominee” and you know, they nominate a Russian corporation, for example. |
| 00:16:37 | JM: | Correct. TIP: So, as Jeremy’s example just highlighted, real estate transactions in Australia have been a focus of AML/CTF reforms due to the sector’s susceptibility to financial crime. Real estate provides an opportunity for criminals to launder large sums of money by disguising ownership, inflating property values or using complex corporate structures to conceal illicit funds. Prior to these tranche 2 reforms financial institutions, money remitters, digital currency exchanges and gambling service providers were subject to AML/CTF obligations requiring them to conduct customer due diligence, report suspicious transactions and maintain compliance programs. However, real estate agents and lawyers – those often involved in real estate transactions – were not covered under the AML/CTF regime. A 2015 AUSTRAC report highlighted that real estate is an attractive money laundering method because it’s relatively simple and requires little expertise. The Australian Federal Police has also identified real estate as a significant money laundering channel. Over the past two years, 57.5% of all assets restrained by the AFP’s Criminal Assets Confiscation Taskforce were commercial and residential properties. Criminals often use complex corporate and trust structures to obscure beneficial ownership, making it difficult for authorities to trace illicit funds and additionally, some use third parties to purchase property on their behalf that further complicates enforcement efforts. Cross-border property purchases are another area of concern. Buyers from high risk jurisdictions may acquire property without clear commercial reasons. This could include leaving properties vacant or paying well above market value. This type of activity not only facilitates money laundering but can also artificially inflate property prices, making it more difficult for legitimate buyers to enter the housing market. The AML/CTF reforms extend obligations to real estate agents and lawyers requiring them to do the things that AML/CTF covered entities have had to do, which in the context of real estate includes identifying the true owners of properties. Additionally, the Government is considering whether property management and leasing services should be included under the expanded framework, given the risks that have been identified by the AFP. Currently money laundering risks in real estate are primarily managed through due diligence conducted by financial institutions, as most property transactions include a mortgage. Most Australian real estate investment trusts are already subject to AML/CTF requirements due to their financial services licenses, meaning that some investor due diligence is also in place. However, when properties are purchased in cash, these transactions are bypassing these checks entirely. To prevent unnecessary duplication of compliance efforts, the reforms may allow real estate professionals to rely on due diligence already conducted by other regulated entities. So what we’re often talking about is things that may raise a risk or raise a suspicion and it’s not saying that you have to prosecute that and say, “yes, that is going to be a breach of law,” but the idea is sometimes having that gut feeling that you’d be uncomfortable. Now, what I would say to lawyers is it’s quite a high standard. You don’t want to be reporting everything. It’s not that, “hey, I saw something in the paper. I’m really concerned. I will report it.” That’s already in the public domain. It’s when you’ve got a concern – there may be the movement of the proceeds of crime, there may be a breach of law – those are the things that you’re looking to report to AUSTRAC and like I say, again, that may be the counterparty, not your client. So while we won’t do chapter and verse on privilege, at least, that’s recognising that you’re likely to have less issues with privilege with the counterparty. |
| 00:19:55 | DT: | Yeah, absolutely. Especially where you are reporting on the activities of a counterparty. How does that interact with your responsibilities to your own client who – take that example of the nominee purchaser a day before completion being an entity in a sanctioned jurisdiction – not to say they’re reckless, but they’re relatively unconcerned about your anti-money laundering obligations. They want the transaction to complete in the shoes of a listener who’s in that situation, what would you be doing? |
| 00:20:21 | JM: | Yeah, it’s actually really interesting, that’s often when I become involved because you actually advise your client on the due diligence and the risk nonetheless. So what you are often doing is saying, “well, we’ve identified this issue.” You’re in some form going to need to tell the client or at least explain that to them; do they want to proceed with the transaction? Here are some of the issues or concerns but that’s sometimes that iterative process you have to go through and that’s why actually reporting of suspicions and dealing with anti-money laundering is complex. It’s hard to deal with it in the academic, it’s almost defined down to every situation but we have that challenge at the moment. Transactions happen every day where there will be potential issues that arise and that’s often where I’m and my team are brought in to say, “let’s advise on the risk. How do we do this in a compliant way?” And, in speaking to lawyers about this challenge, what I find is they say, “we’re actually in a predicament at the moment. We don’t often know whether we should allow for the transaction to proceed or keep acting.” So I think what we have to recognise is this isn’t something which is just you. It may actually provide a useful solution to some of these situations because the idea is if a lawyer reports that suspicion to AUSTRAC, they have a legal defense to the Criminal Code around money laundering or the movement of proceeds of crime. So it’s actually there in a way sometimes to help but I appreciate this is nuanced. It’s going to be new and difficult for people and like I say, it has to be down to every factual situation. |
| 00:21:46 | DT: | Yeah, absolutely and in some ways that sanction example is almost an easier one because you can say to the client, “well, there is a legal impediment to you proceeding with this transaction for you.” It’s a different story where it’s suspicious in an anti-money laundering obligation sense but the entity is an Australian entity or something of that nature and those suspicions arise on other grounds. |
| 00:22:04 | JM: | And I’ve got to touch on it now because the anti-money laundering experts listening to this will be saying, “mention tipping off.” Also, if you report to AUSTRAC, you can’t tip anybody off saying that you’ve made that report. So you could advise on the substantive issue but once you’ve reported to AUSTRAC, you can’t tip off the entity you’re reporting about be cause you wouldn’t want them to flee the jurisdiction or shred documents or do things of that nature. |
| 00:22:27 | DT: | Yeah, absolutely. So we’ve got a good idea of what this sort of transaction might look like. I guess in the extreme, we’ve got that kind of Cayman Islands corporation, difficult to identify who the officers are, that sort of situation. As you’ve said, it’s more nuanced, it’s always going to be about the particular facts and circumstances and I think as difficult as this is to codify, it’s perhaps some of the best advice you can give, which is to trust your gut. If something seems wrong, then that’s an opportunity to look into it further. Knowing what we know now about how we might identify one of these transactions, what are some of the steps required in terms of due diligence on a transaction? I suppose getting the information to help our gut decide whether or not to be concerned. |
| 00:23:04 | JM: | Yeah, correct. So taking it from a legal perspective, you always first do a risk assessment of your entire firm, where you provide designated services. So what activities are captured, what’s the risk based on customer profile, based on those types of services, who you deal with and the geographic risk as well. Then when you get down to a particular client, you would assess that client and you would do due diligence on them, the KYC – so obtaining information about who their directors and shareholders are, their beneficial ownership, if it’s an individual, potentially passport driver’s license or things like digital ID and then you’ve actually got to assess the matters, so thinking what are the risks of the counterparties and the transaction involved? So that’s actually quite a number of steps but if you do that risk assessment of all of the services you provide, first you’re going to have an understanding of the kind of universe of issues that might arise, then when you look at a particular customer, I work with a lot of regulated entities and Australian Stock Exchange listed entities, that gives you a lot more comfort, right? But if you’re dealing with individuals, that could be quite hard. It may be a one-off transaction. You may not deal with them often, so that may pose some risks. It also, as we referenced before, there may be a complex structure that sits behind it. Then when looking at the matter, what type of advice we’re giving, what’s the nature of the transaction and who are the counterparties involved? Those are very much the type of things that you want to be looking into and it’s when a risk may arise. So if you identify something that may be through that due diligence or it may be through the course of the transaction. So just to take another anecdote or example of that, looking at what the source of funds and source of wealth. So with your customer, they may look, on the face of it, to be fine but then you actually see the source of their funds have come from something nefarious that may be of concern as an example. |
| 00:24:54 | DT: | So for example, someone who has an offer of finance from one of Australia’s big four banks, very low risk. You kind of understand how that source of funds works. Someone who doesn’t appear to have a high profile, legitimate business or source of income but seems to have $4 million in cash lying around maybe a little bit higher risk. |
| 00:25:14 | JM: | Correct. Or as an example, it’s a front person for organised crime. So they themselves don’t appear to have any immediate concerns but when you look at where that wealth has come from, “oh, they’re connected to ex-organised crime, you know, offshore, sort of organised crime entity or other syndicate,” that’s where you start to have alarm bells. So that’s why you often need to go that step further, just beyond the customer itself. |
| 00:25:39 | DT: | Got it and I think that preparatory step you mentioned is also a good one, which is before you think about the due diligence on a specific transaction or a specific customer, you know, what fields is your practice involved in that could pose a risk, right? Conveyancing is a great example of that. Basically, every example we’ve discussed in our interview so far has involved a real estate purchase, right? So identifying those spheres of your practice that are higher risk or lower risk and where you might take additional due diligence steps because of that. |
| 00:26:06 | JM: | Yeah, that’s right and the other ones that lawyers need to be mindful; movement of funds through the trust account. So that being a regulated activity but also M&A transactions. So we may see the vast amount of movement of funds through a transaction. So these are the types of services that would be captured. |
| 00:26:22 | DT: | Yeah, absolutely, because I suppose they involve the intermingling of funds, don’t they? So we think about the sort of red flags that might appear in any kind of practice, if a client volunteering to put a large amount of money in your trust account and withdraw it at a future date, that’s a red flag around money laundering for that. |
| 00:26:37 | JM: | Really tangible and practical ones is lawyers can forget that even just the payment of your bill. I’ve been in firms where a client’s accidentally paid the bill 10 times or 100 times because they added a couple of zeroes, then “please pay the funds back out.” Is that the laundering of funds? So we have to be really mindful of the trust accounting procedures but also other procedures – repayment of funds. The other one I have seen in firms before is where you get an email from the trust accounting team saying, “oh, we’ve had these funds deposited. We don’t know where it’s come from. What transaction does it relate to?” |
| 00:27:10 | DT: | Oh, everyone’s seen that email right? |
| 00:27:12 | JM: | Correct and always as an anti-money laundering expert, that raises a concern, right, because if you don’t know how you’ve received those funds and who it’s for, while it’s more likely to be an administrative issue, that could be the end share of money laundering. |
| 00:27:24 | DT: | Yeah, absolutely. Alright, now, we’ve been talking about this in kind of a one size fits all approach. “These are the things that we should all be doing. These are the red flags we should all be looking out for,” but the reforms that actually talk about a tailored approach to AML. What do we mean when we’re talking about a tailored approach? |
| 00:27:39 | JM: | Yeah. The Financial Action Task Force, which is the global body that reviews each country’s legislation – known as a mutual evaluation – it’s always understood that the Financial Action Task Force – FATF – talks about the risk based approach. So every legislation in each country and related to anti-money laundering needs to be risk-based. And the idea is that if you’re a large bank, your controls and the amount of money that you can spend on compliance is likely to be different to the very small one person law firm or small real estate agency. So the idea is that you should put controls in place which are tailored to your risk and that is based on the risk assessment. So talking about what we could call the small end of town, that really needs to be things which are easy and effective. So taking an example; most small law firms won’t be doing a huge amount of conflict checking because they know their practice well, they don’t necessarily have a large number of partners but when they onboard a new client, they will look at things around their details to make sure they’ve got that right in their billing system. If the funds are going through the trust account, they’ll already be doing a level of due diligence in understanding that. We need to augment that process to overlay the anti-money laundering controls but we shouldn’t be doing something burdensome and entirely different. So taking those controls, if you’re onboarding somebody to your practice management system and you’re doing your trust accounting due diligence, getting the information for that, you may just be asking for additional information and what you need to do is therefore document that and the anti-money laundering compliance policies currently programs and the idea then that you are able to do that for each client and matter as you onboard it, that is regulated and hopefully that lessens the burden. Other things that we need to be thinking about is also training of staff. So this is a really good example. Listen to podcasts, listen to training, listen to webinars. You have to do a level of training and you also have to do a level of due diligence on your employees. We are quite fortunate as lawyers, we have practicing certificates that will deal with a lot of the due diligence there but the idea is with these controls, you therefore harden the ability to receive funds that would otherwise be of concern, as we’ve discussed about and then there’s things like reporting to AUSTRAC and that’s done through online processes and shouldn’t be too burdensome on the firm itself and having to set up the technology. So I make that point because when we’re looking at how small entities comply, it shouldn’t be something which means you have to purchase a load of new technology. It shouldn’t be something that should take copious hours but the point I would make early is, yeah, approach this now learning, understanding that we’ve got 12/15 months to comply. So take that time to learn about this so that it doesn’t feel a rush at the end to enrol with AUSTRAC and then get all of these processes and systems in place. |
| 00:30:26 | DT: | Absolutely. And from the perspective of training, I think about it a little bit like the anti phishing training or cybersecurity training that is ubiquitous in law firms and businesses of basically any shape, large and small. We kind of accept that’s a social engineering risk and that there’s just a base level of awareness about that risk that everyone needs to have. It’s not burdensome. We do it once a year. It takes 30 minutes but it’s a huge boon in, as you say, hardening the practice against this risk. I think anti-money laundering might fall into that same category of kind of, “these are the social engineering risks that you may be posed with.” It’s analogous in the sense that cyber threat actors also target law practices as the soft underbelly of entities that otherwise have quite strong security practices like banks and financial institutions. I’m glad you mentioned the proportionality of the due diligence required because anyone who’s listening who’s been in practice for any length of time knows that this is a customer service business. It’s right there in the name. It’s a service business and we do like to make things easy for our clients, right? I can see there being a vulnerability or a risk for practitioners who don’t want to impose all this stuff on their clients. “Oh, I don’t want to ask them for all that stuff ’cause it’s too hard. I want them to have a good experience, so I’m not going to do that due diligence.” There’s going to be an art, isn’t there, in making it seem easy but complying with what you have to comply with. |
| 00:31:50 | JM: | Yeah. I think approaching this is about being very practical. I’ll give another analogy. I was asked the other day for a certified copy of my passport. Even I find it burdensome when I’m asked for it and I think, “oh, I’ve got to get this certified by one of my colleagues.” There’s as much information on the internet, if you Google me on my profile, on my LinkedIn, the fact that I’m a solicitor regulator register with New South Wales Law Society. So there’s a lot of information out there already, particularly on companies. You referred to company registers before – that information’s accessible. I think what is challenging is when you’re dealing with an individual but what you try and get in the practice of doing is actually saying when they turn up in a reception or when you deal with them the first time, ask them to bring in passport, driver’s license, take a photocopy of it, or if you’re dealing with them online, it’s often saying, “yep, just here’s the pack of information that we’d need early” and try and make it as easy and tangible as possible. Also, thinking about regional and remote communities, often the lawyers may be the one or two lawyers in town and they actually see these people in the local supermarket. So I think there’s an understanding as well that we are dealing with clients in person and you understand a good amount about them and sometimes actually be recording that information and just trying to document it but I think we have to be very practical with how we conduct due diligence. I think we sometimes get a bit formulaic and that’s where people start to push back. So I hope through this, there’s greater understanding of what we can do to meet those requirements. I would also just say, let’s utilise things like the digital ID, which is being proposed and starting to be implemented by the Australian Government. So the idea is that you don’t actually need to give your passport or driver’s license away, it’s just saying that you’ve been verified through that system because a lot of that information is centrally held. I would also like things like a free and open companies register. You’ve got to manage privacy and there are challenges and concerns there but also beneficial ownership. So let’s make this easier. With 17-18,000 reporting entities going to over 100,000, I think we have to make this a bit simpler. One final point I would make is also reliance. So can we work with others who are collecting this information? Say, “you’ve got it already, can you provide it to me or can I rely on the fact that you’re doing it?” So where you’ve got a real estate agent and a lawyer, you may be collecting the same information from the person. They may have a mortgage, so the bank will have that. They’ve got a bank account, so they’ve already been verified by them. So we have to try and avoid the situation where a person gets verified by seven different entities when really we’re all trying to achieve the same thing. |
| 00:34:28 | DT: | Absolutely and we live in this complex regulatory environment where sometimes we’re pulled in different directions, right? We were talking about changes to the Privacy Act, small businesses will shortly be subject to the Privacy Act and we were talking with a privacy lawyer about the principle of least data, what is the least amount of information you can hold to reduce the risk for the people that you hold personal information about? TIP: So, David just mentioned an episode where we spoke about the principle of least data. That episode is the first in our two-part privacy series with Alec Christie about the, at the time, proposed reforms to the Privacy Act. This was following the Attorney General’s review of the Act. Those are good ones to listen to if you’re thinking about issues you might need to be aware about adjacent to corporate advisory. The one we specifically mentioned the principle of lease data in is episode 83. So that one’s called the ‘Privacy Parables Understanding Australia’s Privacy Act in the GDPR Age’. You should go check it out. I remember with the Optus breach last year, a copy of my driver’s license was leaked and I thought, “well, why did they need to keep my driver’s license, right? Once they’d identified who I was, what purpose did they have for holding onto it” And so we have that same issue, right? On the one hand, AML regulation requires that we identify our clients, especially where we’re acting for individuals, by looking at these documents. On the other hand, do we really need to retain them once we’ve done that because we might then be increasing our attack surface from a cybersecurity perspective. |
| 00:35:53 | JM: | Absolutely and look, we’ve seen that and it’s one of the great challenges where, particularly with scams at the moment, that’s something which is of great concern to the community. You spoke about privacy, data security, cyber breach. You don’t want the smallest entities with the highest cost burden, having to put much greater cybersecurity controls in place. So while I understand some of the challenges about it, I do agree that’s one of the things of digital ID, that information is already there and there’s sometimes this conversation or this answer that doesn’t create a new honeypot of information. I think the Australian Government’s already got our passport details and all of that information, so it is centrally held somewhere, it’s just the ability to access that and say, “yes, this is this person,” but you’re right, not having to hold that. And we referred to risk-based approach before, if it’s a domestic Australian individual, a resident or a citizen, the risk is likely to be relatively low anyway. I think what we are often talking about from a money laundering perspective, it’s where it is cross border, it’s where it’s in a particular high risk jurisdiction and complex structures. So I would just encourage people to try and make that approach risk based. The other piece is sanctions is also part of these new anti-money laundering measures. So again, when you’re screening for a sanctioned individual or entity, if you are dealing with somebody in the local suburb down the road, they’re very unlikely to be a sanctioned person. They bank with a local, domestic, Australian bank. If they’re being banked, they’re very unlikely to be a sanctioned individual. So the level of screening and due diligence needs to be commensurate to that risk. |
| 00:37:28 | DT: | Yeah. Don’t ask your own brother or sister for 100 points of ID on their conveyance, that sort of thing. |
| 00:37:33 | JM: | Correct. That’s absolutely right. |
| 00:37:35 | DT: | Yeah. Now, we talked a little bit about this before but maybe we’ll go a bit deeper on it. AUSTRAC has also proposed some changes to information sharing regimes to improve the investigation and regulation of anti-money laundering. What does this look like in practice? |
| 00:37:48 | JM: | So what sometimes gets forgotten about the regime, it’s seen as compliance and a regulatory burden. The actual purpose of it is to generate intelligence for AUSTRAC as regulator but then also known as the FIU, the Financial Intelligence Unit, they share that information, if important, with relevant law enforcement. So the Australian Federal Police or state and territory based police. So the idea of having a financial intelligence unit is when you report these suspicions and other information, they can collate it, look at the trends and hopefully help identify crime or help in the investigation of that crime and that gets provided therefore to law enforcement for that purpose. The idea of greater intelligence sharing is saying, well, if we have one financial institution reporting a suspicion but we also have a real estate agent and a lawyer doing the same, they’re doing that each independently but could there be a world where they actually start to share information between them where they say, “look, we’ve identified this issue. We want to make you aware of it because we therefore have greater understanding of the potential concern, the potential laundering of money or other illicit activity.” So the idea being that if you could share that information, it would make for a bit of an intelligence profile. So taking another example, we often find between banks, money gets moved but they’ve only got one piece of the picture. So they’re often called things like mule accounts – that’s where an account may be used and taken over by another person for an illicit purpose. Money is moved from that account from one financial institution to another very quickly and then offshore because the banks cannot communicate with one another because of tipping off. They therefore can’t combat the crime. They can only report to the regulator. So the idea of intelligence sharing, information sharing, is could we put in the appropriate governance and other controls to say where we identify certain activity and there’s a nexus to another reporting entity, another regulated entity like a bank, should we share that information in that instance because it would build a better intelligence profile. |
| 00:39:57 | DT: | And is this, I guess, a capability or a requirement? In the sense that a bank in that example, is prevented from sharing that information because of tipping off requirements but outside of the four corners of the anti-money laundering regime, I suppose they may have some customer confidentiality or privacy obligations but as solicitors, we owe even higher obligations than that – privilege can be waived only in very exceptional circumstances. You’re entitled to maintain privilege even if it involves criminal offences and most importantly, that privilege is the client’s privilege, not our own. So how does that information sharing or proposed information sharing regime interact with privilege? |
| 00:40:36 | JM: | That’s the real challenge, right? So that’s why the ACT doesn’t speak very specifically to what’s required. So what it’s saying is that there can be a level of information sharing but it’s got to be the appropriate governance and other controls in place and that’s the challenge, right? We now have to design what that looks like. I think of it this way – there might be a higher bar or a threshold. I’m very fortunate, previously had provided pro bono advice to the International Center for Missing Exploited Children, I’m now a non-executive director of that entity, they have a collaboration working group with the banks payment providers and AUSTRAC and others. The idea is to promote that information sharing but taking an example, if it was for the exploitation of children or online child exploitation, you’re going to want greater information sharing to combat this. So these are the types of scenarios where you could put governance arrangements and other controls in place to say, “for specific instances, can we share a greater amount of information?” You touched on privilege. That is one of the key challenges for lawyers and has been a lot of the engagement with the Attorney-General’s department but also AUSTRAC as regulator. When you think about privilege, we talked earlier about you’re often not going to be reporting on your own client because there are concerns around privilege and the Financial Action Task Force does have guidance in place that really says you shouldn’t be reporting privileged information. So I take it back to that earlier point. It is often about reporting on the counterparty to a transaction where there’s likely to be less of a privilege issue but that’s where I think lawyers have to be mindful is saying, “what are my obligations re privilege, privacy, tipping off but where could there be instances where I can report to the regulator but also then share information of others within the relevant controls.” But yes, to be determined around those information sharing protocols. |
| 00:42:23 | DT: | There’s never any easy answers in this game. Is there? |
| 00:42:25 | JM: | No and look, I mean, you’re a lawyer, so not to lecture on it but the legislation and the rules often put the parameters in place. What the AML program and policies are designed to do is then you have to work out the best way to do it. So this is not overly prescriptive. So that’s why we as industry often have to work together to say “what is actually the market standard and how can we do this?” Parliament is not going to designate every type of information sharing that’s up to industry together with AUSTRAC and others to ultimately look at what that should be like. |
| 00:42:58 | DT: | Now, we’ve talked a little bit about how technology influences, well, both anti-money laundering and money laundering. You mentioned briefly that there are tools that make reporting easy to AUSTRAC. At the same time, we also mentioned that when the act first came into force in 2006 or when it was first legislated in 2006, tools commonly used by organised crime organisations, by criminal organisations like cryptocurrency didn’t exist. So let’s start with the white hat side. What tools exist to make it easy to comply with these requirements that law practices should be aware of? |
| 00:43:33 | JM: | Yeah, so taking international sanctions as an example, so is a person sanctioned by DFAT and the Australian Sanctions Office. There is a spreadsheet online that you can do search of to see all of the sanction persons involved. However, what’s more commonly used is screening tools out there that say, “if I put in this person’s name or this entity’s name, it will not only come up with whether they’re sanctioned in Australia but the US, UK, EU, the UN but also are they owned and controlled?” So often we use technology things like screening tools that can do a whole number of things at once. I’ll add onto that – they can also assess whether it’s a politically exposed person, which is one of the requirements under the AML Act and it has things like negative news and other things that you may be concerned about, like regulatory fines. So what these tools enable you to do is if you put in that name, you should get a really good risk profile of who you are dealing with. You still have to do that other customer due diligence, getting the information, understanding their beneficial owners but these tools are therefore to try and streamline it. There is a cost for those types of products but hopefully with these new regulated entities coming on board that can be streamlined. So one of the things which is in consideration at the moment is for eConveyancing, could an econ conveyancing platform actually do the screening within it? So it would benefit every party re their compliance to say, “well, when you’re doing this transaction, can we screen to see whether you’re sanctioned or a politically exposed person?” That also helps with the reliance and reducing the burden. So we have to see technology effectively as an efficiency tool but you know, this is something that I think requires greater exploration. So that’s how I think we need to be really using technology to create those efficiencies. TIP: So Jeremy just mentioned the AML/CTF dealing with politically exposed persons or PEPs. A PEP is someone who holds a high profile public position in a government, body or international organisation, either in Australia or overseas. This category also extends to their immediate family members and close associates as they may have access to the same networks of power and influence. PEPs are often involved in key government functions such as budget management, procurement, developmental approvals and grants. Examples can include heads of state government, ministers, senior execs, high ranking judges, top military officials and central bank governors, as well as executives and board members of international organisations. Due to their influence, PEPs can be vulnerable to bribery, corruption and financial crime, making them a potential risk for money laundering and terrorism financing. This is why the AML/CTF regulations require businesses to identify and monitor PEPs as part of their risk management strategies. |
| 00:46:23 | DT: | And on the other side of the coin, the technology that assists in money laundering, I suppose that gives the impression of complexity but there’s some pretty common sense steps to take there. Not accepting payment of your bills in Bitcoin might be one. |
| 00:46:34 | JM: | Correct. You know, the classics of not accepting it in cash, right? So I’ve worked in in-house teams where somebody has turned up with cash to the reception and sometimes that can be cultural, right? They’re saying, “I’ve got a house deposit, I’ve got this amount of cash.” Well you direct them to the local bank and say, “please deposit it there.” You don’t want to be accepting cash. It can both be a money laundering risk but it’s also a safety risk, right? You don’t want to be handling that vast amount but that’s right. There will be certain controls that you put in place to say things that we just won’t do. “We may not accept payment and cryptocurrency. We may not accept payment volumes of cash, particularly over $10,000,” as an example. |
| 00:47:10 | DT: | Yeah, it’s a high tech version of a very old problem, right? |
| 00:47:14 | JM: | That’s right and some of this stuff is more simple than we realise. We actually deal with anti-money laundering controls every day because you’re interacting with your bank, your payment provider. So we actually, as citizens, have a really good understanding of this already. It’s just now going that we actually have to take some of those more practical steps to try and both comply but also prevent crime. |
| 00:47:34 | DT: | Now, as I said at the top of the episode, the Bill has now passed. It will come into force in 2026. |
| 00:47:39 | JM: | That’s right, these new reporting entities having to enroll before 31 March, 2026 and then actively comply 1st of July, 2026. |
| 00:47:48 | DT: | That might sound like it’s a while away but I’m sure it will go very quickly. What can we start to do now to prepare? |
| 00:47:54 | JM: | Yeah, so you don’t have to wait for the rules to be finalised but what new reporting entities can do is actually conduct that risk assessment now. So look at the designated services that they would provide – those won’t change. So what will be captured? What’s the risk of providing those to particular customers based on geography, their type of structure? Once you’ve got the risk assessment in place, you might want to start looking, do we actually have all of our existing customer or client data all in one place? It’s very hard to do your anti-money laundering checks if they’re on seven different systems. So actually thinking about what’s the technology that we hold this and where’s it secured? Thinking also about what training and certification do you need to do. So one of the things we haven’t touched on and is very important is your AML compliance officer. So you need to nominate somebody who’d be effectively responsible for AML compliance within your organisation. So is there a person that we want to get to a level of training and certification so that they come up to speed and being able to identify who that person or persons may be so that we’re able to go through that process. It’s starting to look at, we’ll actually systematise some of this, so what are the things that we can start to say, actually, “let’s say we’ve got 500 clients. Can we actually do a level of due diligence on them already so that we don’t have to front end that when we become regulated.” So you may have 400 of your clients are actually a lot of repeat business, so we’re actually going to do a level of that due diligence now based on information that we have on file so that when we come to being regulated, we’ve got ahead of the game. So I think it’s worth likely reporting entities starting to think about this and if you start now, it’s going to be a lot less of a burden later on. Keeping in mind as well that a lot of the expertise out there, whether it be legal, consulting and technology, they’ve probably got a bit of free time now. When 100,000 new entities are trying to do this or 90,000 new entities are trying to do this in 12 months time, it’s going to be very scarce. |
| 00:49:56 | DT: | Yes, absolutely. Now, Jeremy, we always finish with a question for our listeners who have recently joined the profession or are yet to join, it might still be students. This seems like one of those areas, a bit like billing, a bit like estimating costs, a bit like conflicts, all the stuff that when you’re a young lawyer, you think, “well, that’s someone else’s problem, right? I’m supposed to do the work, record the billable time, put my time sheets in and we’ll leave it to the partners,” especially in a large law firm, “the people on the administrative floor to do all that stuff,” but we all have a role to play and from March 2026, individual lawyers will have their own responsibilities to contribute here as employees or officers of reporting entities. If you’ve got one tip for our newly admitted or soon to be admitted listeners about how they can contribute to their own organisation’s AML compliance, what would that be? |
| 00:50:47 | JM: | This would probably be a long answer but I’m really passionate about it. First two or three years I was doing this, I used to explain to my friends and former colleagues and say, “I don’t actually know why you do that funny compliance thing.” You know, with the growth of this over the last 10 years and particularly with enforcement action, everybody understands what I now do. So it’s become a really hot area. I probably get a call or an email every week from somebody new to the profession going, “I want to do what you do.” It’s something that people are passionate and interested about. I have a slight question for you. Do you know how many lawyers there are in Australia, in the legal profession or practicing lawyers? |
| 00:51:22 | DT: | I think there’s around 90,000. |
| 00:51:24 | JM: | Yeah, it’s got to 107,000 according to the Law Council from last year, there’s going to be 107,000 estimated reporting entities, which means you need the same number of AML compliance officers, which we’re referring to before, maybe just part of their role. So we have to increase that by 90,000 in the next year. So if I was speaking to any law student or somebody new in the profession, if you’re passionate about this area, whether it’s internal compliance or advising on it, this is a huge growth area. We’re effectively trying to create a population of people the same size is the legal profession within a year to say “we need to comply with this.” So if you’re trying to find a job, you’re passionate about this area, you’re struggling to find a job, this may be a really good avenue. So do some education, listen to podcasts like this, get involved. There’s going to be a lot of people later in their profession saying, “I don’t want to be responsible for this.” If you’re new or in the mid stages of your career, this could be a really good opportunity to step up and it’s exactly what I did. I traveled overseas. I got to do this in-house. I moved between a couple of firms and got promoted during that time and I became a really passionate advocate for this area but it’s definitely enabled me to develop my career. So I would say to anybody, get involved and see this bit as an opportunity, not just as a regulatory compliance burden. |
| 00:52:42 | DT: | That’s a great point. Over the next year, there’s a real opportunity for recent entrants to the profession to specialise, to find their niche and to offer something really valuable, not only for their employer but that’s really pro-social, that helps to combat financial crime and combat the funding of all these terrible things like child exploitation and terrorism and organised crime. So a great opportunity for anyone listening who has found it interesting, as I’m sure many have. Jeremy, thank you so much for joining me today on Hearsay. |
| 00:53:08 | JM: | Oh, I appreciate it. Thank you. |
| 00:53:19 | TH: | As always, you’ve been listening to Hearsay the Legal Podcast. We’d like to thank our guest today, Jeremy Moller, for coming on the show. Now, if you’re in the corporate advisory space, why not go check out our episode on another area you might need to be aware about; modern slavery. We have an episode with Eric Boone from Madison Marcus. That one is episode 132 and it’s called ‘Combating Modern Slavery: Compliance Obligations and Beyond’. If you’re an Australian legal practitioner, you can claim one continuing professional development point for listening to this episode. As you know, whether an activity entitles you to claim a CPD unit is self-assessed but we suggest that this episode entitles you to claim either a substantive law point or a practice management and business skills point. You can take your pick. For more information on claiming and tracking your points, head on over to the Hearsay website. Hearsay The Legal Podcast is, as always, brought to you by Lext Australia, a legal innovation company that makes the law easier to access and easier to practice and that includes your CPD. Now, before you go, we’d like to ask you a favour. If you’re enjoying Hearsay the Legal Podcast, please consider leaving us a Google review. It helps other listeners to find us and ultimately it keeps us in business. Thanks for listening and we’ll see you on the next episode of Hearsay. |
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