The regulator of Australia's anti-money laundering regime, Austrac, has warned companies in the finance industry that they should not use the prosecution-free period that applies to rules that take effect on December 12 as an opportunity to delay action.Austrac director of compliance and enforcement, Julieann Ahern, said yesterday that by December 12 she would expect to see companies at least at the stage of having signed-off business plans for implementing the know-your-customer rules that take effect on that date.Speaking at an industry forum organised by Veda Advantage, Ahern said: "We worry about slippage at the back end. Companies need be taking reasonable steps now."The Anti-Money Laundering and Counter-Terrorism Financing Act, which was passed in December last year, is being implemented in stages over a two year period. December 12 is the implementation date for Part 2 of the Act, dealing with identification procedures.The Act says: "A reporting entity must carry out a procedure to verify a customer's identity before providing a designated service to the customer… A reporting entity must carry out ongoing customer due diligence."The Act provides for a 15 month moratorium against prosecution for breaches of the identification rules. For some companies, particularly those that have not had transaction reporting and customer ID responsibilities before, there will be a temptation to use the moratorium period to delay implementing a program.Ahern said: "What we have seen is that most companies are trying to meet the deadline. When we go out and meet companies we expect to see a project going on."Ahern said another deadline fast approaching was the March due date for filing the first compliance reports, covering the 12 months to December."What we will be looking for in those reports is evidence of strategies for identifying risks in the business, adequate resourcing, allocation of management responsibilities and board roles."We will be looking for adequate controls, reporting lines, communications protocols and processes for review."Ahern said she expected big companies to have relatively sophisticated programs in place already. Austrac's focus will on smaller organisations with fewer compliance and risk management staff.