It is certainly the case that criminals often use the accounts of their relatives to wash money. With this in mind, Australia's financial intelligence unit and anti-money-laundering regulator has changed its AML/CTF Customer ID and Verification Rule to help vulnerable HNWs and other people who experience family/domestic violence that might lead to such events.

The rule now dictates that if a customer cannot produce his driver’s licence (for some inexplicable reason AUSTRAC spells it 'license') or birth certificate, or show the bank in question a different address, that bank can use alternative ways to verify his identity.

According to AUSTRAC, financial abuse is a very frequent concomitant (it erroneously calls it a 'form') of family/domestic violence. The abuser (often, in the case of an aged HNWI, a carer) sometimes uses violence and intimidation to stop the victim from gaining access to his accounts, to prevent him from working or drawing income, or to withhold living expenses from him or his offspring.

According to AUSTRAC, it is imperative for anyone (in any financial stratum) who is leaving or has left an abusive relationship to have a bank account that is independent of the abuser.

AUSTRAC collaborated on the rule change with the Australian Banking Association (ABA) and the Australian Israel Chamber of Commerce (AICC) of New South Wales, both of which dreamt the project up and spotted the opening of bank accounts as a 'choke point' for the problem. AUSTRAC also consulted family-violence services and financial-counselling services, many of which offer help to people who suffer such abuse.

Anna Bligh of the Australian Banking Association said: “When fleeing a violent situation it is often not possible to collect documents, or these are sometimes deliberately withheld by a perpetrator. This can make proving an identity to usual bank standards a very difficult barrier to financial independence.”

As far as this publication can see, this is the first regulatory initiative in the world that deals with this problem. One might think that most illicit drug dealers, arms dealers and extortionists would try hard to keep their loved ones as far away from their money-laundering operations as possible, so as to insulate them from being implicated. The truth, however, is exactly the opposite.