Jeremy Moller

Senior Advisor - Risk Advisory Norton Rose Fulbright Australia
Jeremy Moller

Jeremy Moller

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 AML/CTF regulation of real estate agents, lawyers and accountants, known as 'Tranche 2', which has recently passed the Australian Parliament. Compliance for Tranche 2 entities is required by 1 July 2026.  

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

Representative experience

Representative experience

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.
  • International banks - advised numerous international banks on compliance requirements under Australian AML/CTF laws as well as screening of customers.
  • Large real estate entity - advising on with Australia's AML/CTF Act and Rules, including drafting of risk assessment, policies and procedures. 
  • Tranche 2 entities - advising a number of clients in the real estate and legal sector regarding their AML/CTF compliance and enrolment which is required by 1 July 2026.
  • Banks, payment providers and superannuation - undertaking AML/CTF independent reviews for numerous reporting entities. 
  • International airline – advised 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.
  • 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 and Iran. 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 sanction's 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 Russian and Iranian sanctions.
  • Engineering and manufacturing company – advised on the application of defence export controls to component parts used in military equipment.  
  • Equipment provider - advised on the application of defence export controls for transport of goods to intermediary jurisdictions and assessment of end users. 

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.

Rankings and recognitions

Rankings and recognitions

Chambers and Partners: Asia-Pacific 2025 Guide (Australia) - Up and Coming: White-Collar Crime & Corporate Investigations

Admissions

Admissions

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

Publications

Publications

  • 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).
  • Australian Restructuring Insolvency & Turnaround Association (ARITA) Journal, "Government Consultation on Tranche Two Reforms of AML/CTF Regime" (August 2023). 

Speaking engagements

Speaking engagements

  • 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 Payments and Compliance".
  • June 2022 - Macquarie 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 regarding "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 regarding "Navigating Tranche 2 and Grey Listing: Implications and Strategies".
  • May 2024 - Association of Certified Anti-Money Laundering Specialists (ACAMS), Moderator regarding: "AML Reforms - Impact on Existing Reporting Entities".
  • June 2024 - Association of Certified Anti-Money Laundering Specialists (ACAMS), Australasian Conference - Panelist for "Digital Dilemmas: Ramifications of Digital ID When Verifying Customers".
  • October 2024 - Assocation of Certified Anti-Money Laundering Specialists (ACAMS), Moderator regarding: "AML Reforms - The Future of AML/CTF in Australia."
  • February 2025 - AML Edge - Numerous panels related to Regulation of Tranche 2 entities.
  • February, June and July 2025 - Association of Certified Anti-Money Laundering Specialists (ACAMS), Moderator of numerous panels relating to AML/CTF Reforms and the Regulation of Tranche 2. 
  • May 2025 - Macquarie University Financial Integrity Hub - Integrity Insight: Financial Crime Summit, Moderator regarding "Tranche Two Entities: Domestic Changes and Global Lessons".
  • June 2025 - Association of Certified Anti-Money Laundering Specialists (ACAMS), Australasian Conference - Panelist for "Level Up: Elevating Your Risk Management Strategy Amid Regulatory Reform" and "Putting the 'p' into KYC: Understand Risk, Trust your Decisions, Open Opportunities."

Memberships and activities

Memberships and activities

  • 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 Reference Group Member.  
  • International Centre for Missing and Exploited Children Australia Board Member and Chair.
  • Member of the Australia and New Zealand Sports Law Association (ANZSLA).

Languages

Languages

  • English

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