Jeremy Moller

Senior Advisor - Risk Advisory
Norton Rose Fulbright Australia

Sydney
Australia
T:+61 2 9330 8086
Sydney
Australia
T:+61 2 9330 8086
Jeremy Moller

Jeremy Moller

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Biography

Jeremy Moller is a risk advisory lawyer based in Sydney. He has over 15 years' experience working in Australia, the United Kingdom and New Zealand as a lawyer specialising in anti-money laundering, international sanctions and export controls as well as foreign transparency and influence. 

Working with a team of multi-disciplinary experts within the firm's risk advisory team, Jeremy acts as a trusted advisor to a number of large financial institutions and corporate clients in relation to financial crime compliance with a particular focus on anti-money laundering (AML) and counter-terrorism financing (CTF). He is experienced in dealing with a range of regulators both in Australia and overseas, including the Australian Transaction and Reports and Analysis Centre (AUSTRAC). His work includes leading, implementing and reviewing financial crime programs, such as conducting business wide risk assessments, as well as advising on litigation arising out of regulatory investigations and acting on Royal Commissions.

Jeremy recognises the importance of both improving customer experience and ensuring compliance. Having led in a risk and compliance function for an international law firm, he has a unique understanding of the synergies between both legal compliance and operational risk management and provides clients with a holistic and commercial approach to regulatory issues. Based on this experience Jeremy and the risk advisory team have the relevant expertise to advise clients on the likely AML/CTF regulation of real estate agents, lawyers and accountants, known as 'Tranche 2', which is presently being considered by the Australian Government. 

Jeremy sits on the Ethics Committee of the New South Wales Law Society, is an Advisory Board Member for the Australasian Chapter of the Association of Certified Anti-Money Laundering Specialists (ACAMS) and is a Member of the AML/CTF Working Group for the Law Council of Australia. He also has a keen interest in governance and assists a number of not-for-profit entities with their legal and regulatory compliance.

Professional experience

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  • Barrister and Solicitor of the High Court of New Zealand 2010
  • Solicitor of the Supreme Court of New South Wales 2016

Anti-Money Laundering and Counter Terrorism Financing Compliance

  • Solicitor Assisting the Inquiry by the Honourable Patricia Bergin SC under section 143 of the Casino Control Act (NSW). 
  • Large US bank – advising the Sydney Branch of a large US Bank on a number of separate matters in relation to their international and domestic transaction reporting requirements to AUSTRAC.
  • Wealth advisers – advising a large group of Wealth Advisers on a potential breach of sanctions screening requirements and anti-money laundering laws regarding politically exposed persons.
  • International airline – advising an international airline their anti-money laundering compliance based on differing scenarios involving the purchase or refund of flights.
  • Chief Risk Officer – advised on the anti-money laundering considerations in connection to ASIC proceedings brought in relation to directors and officer's duties.
  • Global money transfer business – advised on the reporting obligations to AUSTRAC for a remittance business engaging in international funds transfer instructions.
  • Financial institutions and investors – advised on compliance with anti-money laundering requirements related to medicinal cannabis given their regulation in Australia and Canada.
  • A publicly listed real estate entity – advised on the establishment of their anti-money laundering compliance program for Australia and New Zealand. This included conducting a risk assessment of each business line, integrating customer due diligence into the existing on-boarding process and providing guidance on the assessment of low, medium and high risk customers.
  • Digital currency exchange provider - advised on the anti-money laundering compliance requirements for establishing a digital currency exchange in Australia.

International Sanctions and Defence Export Controls 

  • Advised on numerous indicative assessment and permit applications with respect to Australian sanctions imposed on Russia. This includes entities operating in banking, oil and gas, transport and professional service sectors. 
  • Financial institutions and multi-national companies – advised on their compliance with international sanctions in jurisdictions such as Iran, Russia, Cuba and Myanmar. This includes the implications of sanctions imposed by Australia, the United States, the United Kingdom and the European Union.
  • Management consultancy - advised on the sale of their Russian based operations due to the sanctions imposed.
  • International airline – advised on the making of overflight payments to the Iranian Ministry of Transport and Russian Ministry of Transport in compliance with Australian law.
  • International airline – advised on the establishment of their sanctions compliance program, including specific Australian law advice with respect to contracting with counterparties in Iran, Cuba and Myanmar.
  • Japanese oil company – provided advice regarding shipping entities subject to Iranian sanctions.
  • Engineering and manufacturing company – advised on the application of defence export controls to component parts used in military equipment.  

Foreign Influence and Transparency

  • Led targeted integrity due diligence, including anti-bribery and corruption compliance, on third party contractors and suppliers throughout Asia and Australia. These reports related to potential investments or mergers and acquisitions that were considered by senior management and boards.
  • Advised numerous clients on the requirements to register when representing foreign principals in Australia under the Foreign Influence Transparency Scheme.
  • Regulation Asia, "The Need for Tranche 2 Reform in Australia" (19 November 2020)
  • AML Intelligence, "A Shadow Down Under – could Australia be added to the FATF Grey List?" (1 June 2021)
  • LawInSport, "Prioritising Consistency & Compliance: A Review of Australia's National Integrity Framework for Sport" (10 June 2021)
  • Australian Restructuring Insolvency & Turnaround Association (ARITA) Journal, "Maintaing Anti-Money Laundering Compliance and Reporting Suspected Proceeds of Crime" (September 2021)
  • Journal of Banking and Finance Law and Practice (JBFLP), "Open Banking in Australia: Competition and Money Laundering, Risks and Benefits" (2021) 32 JBFLP 59
  • Financial Institutions Sanctions Compliance Journal, World Export Control Review (World ECR), "Balancing the scale: Australian sanctions targeting human rights abuse and significant corruption" (October 2021)
  • Regulation Asia, "Combatting TBML Through Beneficial Ownership and Enhanced Transparency" (2 May 2023) 
  • July 2019 - Association of Certified Anti-Money Laundering Specialists (ACAMS) - Panelist on "Tranche 2 - Regulation of Lawyers, Accountants and Real Estate Professionals".
  • June 2020 - Regulation Asia - Panelist for "The Shifting Landscape for Financial Crime".
  • January 2021 - Association of Certified Anti-Money Laundering Specialists (ACAMS) - Panelist on "Understanding Upcoming Changes to Australia's AML/CTF Regime". 
  • June 2021 - Association of Certified Anti-Money Laundering Specialists (ACAMS), Australasian Conference - Moderator for "Examining the Emerging Threats to your Financial Institution's Risk Assessment".
  • June 2022 - Association of Certified Anti-Money Laundering Specialists (ACAMS), Australasian Conference - Moderator or Panelist for:
    • "Risk Management: What's New for 2022?".
    • "Australia and New Zealand: The Value of a Financial Crime Utility in AML/CTF Outcomes".
    • "Sanctions: The Cost of Conscience".
    • "Keeping Pace with Change: Cross-border Payents and Compliance".
  • June 2022 - Macquare University Financial Integrity Hub - Panelist for "Blockchain Intelligence: Cryptocurrency De-Anonymization".
  • August 2022 - Association of Certified Anti-Money Laundering Specialists (ACAMS), Panelist regarding "Independent Reviews".
  • November 2022 - LawAsia Conference, Sydney, Panelist regarding "How Sanctions Affect the Banking and Financial Sectors".
  • June 2023 - Australian Restructuring Insolvency & Turnaround Association (ARITA), Panelist regarding "AML/CTF Regulation and Insolvency Practitioners".  
  • July 2023 - Australian National University, Panelist regarding "Corruption and Human Rights Sanctions".
  • August 2023 - Transparency International Australia National Integrity Summit, Panelist regarding "Anti-Corruption Sanctions". 
  • November 2023 - LawAsia Conference, Bengaluru, Panelist regarding "Wait before you Donate! Regulating Online Fundraising Platforms".
  • December 2023 - Association of Certified Anti-Money Laundering Specialists (ACAMS), Moderator on "The Consultation into Modernising Australia’s AML/CTF Regime and the Road to Tranche 2".
  • April 2024 - Macquarie University Financial Integrity Hub - Integrity Insight: Financial Crime Summit, Moderator on "Navigating Tranche 2 and Grey Listing: Implications and Strategies".
  • Member of the New South Wales Law Society Ethics Committee.
  • Association of Certified Anti-Money Laundering Specialists (ACAMS) Australasian Chapter Advisory Board Member.
  • Member of the Law Council of Australia Working Group for Anti-Money Laundering and Counter-Terrorism Financing.
  • Member NSW Law Society’s Anti-Money Laundering and Counter-Terrorism Financing Reference Group.
  • Macquarie University Financial Integrity Hub Advisory Board Member.  
  • Member of the Australia and New Zealand Sports Law Association (ANZSLA).
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