Senior Advisor - Risk Advisory
Norton Rose Fulbright Australia
Related services and key industries
- Risk advisory
- Regulation and investigations
- Sanctions and export controls
- Sports law
- Corporate governance
Jeremy Moller is a risk advisory lawyer based in Sydney.
He has over 10 years' experience working in Australia, the United Kingdom and New Zealand as a lawyer specialising in anti-money laundering, international sanctions as well as foreign transparency and influence.
Beginning his career in New Zealand during the global financial crisis, Jeremy advised financial institutions on insolvency disputes and enforcement action. Subsequently he has worked in regulatory compliance roles advising entities both internally and externally on their approach in combatting financial crime, and also third party risk management, business continuity and conflicts of interest.
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 and international sanctions. 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.
Jeremy sits on the Ethics Committee of the New South Wales Law Society. He has a keen interest in governance and assists a number of not-for-profit entities with their legal and regulatory compliance.
- 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.
International Sanctions and Export Controls
- 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.
- International airline – advised on the making of overflight payments to the Iranian 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.
- Private United States based bank – advising on their Australian international sanctions compliance obligations and screening of customers and counterparties.
- Developed and marketed a global sanctions compliance product that is sold to clients on a subscription basis. The product includes the sanctions imposed by Australia, the United States, the United Kingdom and Canada.
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 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.
- 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".
- 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 Taskforce for the Inaugural Australasian Conference of the Association of Certified Anti-Money Laundering Specialists (ACAMS).
- Member of the Australia and New Zealand Sports Law Association (ANZSLA).
Navigating financial crime risks: how financial institutions are approaching clients in the crypto-asset sector
Publication | November 18, 2021
Navigating financial crime risks in the time of crypto-assets: What triggers your AML/CTF regime for crypto businesses?
Publication | November 17, 2021
Blog | November 10, 2021
Webinar | October 07, 2021