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OFFICIAL
Dear AS,

Thank you for submitting a request for access to information you believe to be held by AUSTRAC.

In accordance with section 15(5)(a) of the Freedom of Information Act 1982 (FOI Act), I formally acknowledge receipt of your freedom of information request for access to:

"I seek access to all correspondence and documents including the contract itself (identified on the Senate Order as not confidential) for the following:
CN3942923 Palantir Technologies Australia Pty Ltd

In particular, I seek documents regarding the assessments for compliance under the PGPA Act, Commonwealth Procurement Rules, Commonwealth Supplier Code of Conduct and any other relevant legislation including but not limited to the Modern Slavery Act and/or any internal policies for compliance

With reference to the Code, I particularly seek access to documents with efforts to consider the supply chain is not causing or contributing directly or indirectly to human rights abuse and all risk assessments undertaken by AUSTRAC. In addition, any documents outlining the suppliers efforts for risk management and assurance

Finally I seek documents regarding internal considerations of the company such as due diligence conducted extending to management and statements made on attitude towards compliance with domestic and international law, and the Australian public's perception or views potentially on this

This is in the public interest particularly with AUSTRAC’s stated values as a trusted body with foundations of reliability, integrity and transparency. In addition, AUSTRAC’s responsibility for preventing, detecting and responding to criminal abuse to protect the community

All the above applying to the US headquartered business and Australian subsidiary."

Under section 15(5)(b) of the FOI Act the statutory time frame for processing a request is 30 days, within which a decision on access to the requested documents is to be notified. We received your request on 21 October 2024 and the 30 day statutory period for processing your request commenced from the day after that date.

Charges
AUSTRAC may impose a charge for the work involved in providing access to the documents in accordance with the Freedom of Information (Charges) Regulations. If your request for access to documents attracts a charge, you will be notified in writing. Note: There is no charge for documents that contain the personal information of the applicant.

Exclusion of non-SES staff details, and SES staff contact details
AUSTRAC’s policy is to exclude the details (name, position title, telephone and/or mobile number, and email address) of officers not in the Senior Executive Service (SES), as well as the contact details (telephone and/or mobile number and email address) of SES staff, contained in documents that fall within scope of an FOI request. If you require names, position titles and contact details of non-SES officers, or the contact details of SES staff, please inform us so that the decision maker may consider your request.  Otherwise, we will take it that you agree to the information being excluded from the scope of your request.

If you have any questions in relation to your request, or require further information, please contact the Privacy and Information Access team at [email address] and quote reference PIAT-6234.

Regards

Ashley Smith | Manager, Privacy and Information Access Team
Privacy and Information Access Team

Legal and Enforcement Branch
@AUSTRAC  W: www.austrac.gov.au
OFFICIAL

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OFFICIAL
Good afternoon AS,

I refer to your below FOI request seeking access to the following documents:

"I seek access to all correspondence and documents including the contract itself  (identified on the Senate Order as not confidential) for the following:

CN3942923 Palantir Technologies Australia Pty Ltd

In particular, I seek documents regarding the assessments for compliance under the PGPA Act, Commonwealth Procurement Rules, Commonwealth Supplier Code of Conduct and any other relevant legislation including but not limited to the Modern Slavery Act and/or any internal policies for compliance

With reference to the Code, I particularly seek access to documents with efforts to consider the supply chain is not causing or contributing directly or indirectly to human rights abuse and all risk assessments undertaken by AUSTRAC. In addition, any documents outlining the suppliers efforts for risk management and assurance

Finally I seek documents regarding internal considerations of the company such as due diligence conducted extending to management and statements made on attitude towards compliance with domestic and international law, and the Australian public's perception or views potentially on this

This is in the public interest particularly with AUSTRAC’s stated values as a trusted body with foundations of reliability, integrity and transparency. In addition, AUSTRAC’s responsibility for preventing, detecting and responding to criminal abuse to protect the community

All the above applying to the US headquartered business and Australian subsidiary."

AUSTRAC have been working hard on your request since it was received. AUSTRAC are still in the process of identifying all relevant documents captured within scope of your request. Although some documents are readily identifiable (for example the contract itself) AUSTRAC are still in the process of identifying and assessing every document captured within the broad scope.

Identifying the documents within scope, assessing the documents within scope and also having a unusually high number of FOI requests on hand at this point in time has resulted in me seeking a 30 day extension of time from you to process your FOI request. If you were agreeable to the extension, your FOI request would be due on Friday 20 December 2024.

I plan to use the additional time to continue identifying documents in scope, assessing documents identified and facilitating a FOI decision notice that is consisent with the FOI Act.

I look forward to your response to my extension request, thank you very much for the consideration.

Regards,

Ashley Smith | Manager, Privacy and Information Access Team
Privacy and Information Access Team

Legal and Enforcement Branch
@AUSTRAC  W: www.austrac.gov.au

OFFICIAL

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OFFICIAL
Good afternoon AS,

I’m writing in respect to my earlier correspondence below dated Monday 11 November 2024.

I’m hopeful the below correspondence provides enough information concerning the reasons an extension of time is being requested.

I look forward to hearing from you as soon as possible in respect to your consideration of an extension of time. Thank you.

Regards,

Ashley Smith | Manager, Privacy and Information Access Team
Privacy and Information Access Team

Legal and Enforcement Branch
@AUSTRAC  W: www.austrac.gov.au
OFFICIAL

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OFFICIAL
Good afternoon AS,

I refer to the correspondence below. Please respond as soon as possible in respect to the s 15AA extension request.

Thank you very much.

Regards,

Ashley Smith | Manager, Privacy and Information Access Team
Privacy and Information Access Team

Legal and Enforcement Branch
@AUSTRAC  W: www.austrac.gov.au

OFFICIAL

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OFFICIAL
Good afternoon AS,

I refer to the correspondence below, noting the due date for your request is COB tomorrow.

I'd appreciate a response as soon as possible in respect to the extension of time that has been requested.

Regards,

Ashley Smith | Manager, Privacy and Information Access Team
Privacy and Information Access Team

Legal and Enforcement Branch
@AUSTRAC  W: www.austrac.gov.au

OFFICIAL

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OFFICIAL
Good afternoon AS,

I have been trying to contact you without success. There may be an alternate email address you may wish for me to contact you on in respect to this request. Where such an email exists it would be welcomed so AUSTRAC can continue to liaise with you in respect to your ongoing FOI request.

I wish to inform you the legislative due date of your request is now 20 December 2024. AUSTRAC have conducted a s 27 FOI Act consultation in respect to documents relating to Palantir, which is an affected third party subject to your request.

Thank you.

Ashley Smith | Manager, Privacy and Information Access Team
Privacy and Information Access Team

Legal and Enforcement Branch
@AUSTRAC  W: www.austrac.gov.au

OFFICIAL

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OFFICIAL
Good afternoon AS,

I'm writing to you to again seek your agreement to extend the legislative processing time by 30 days.

Although AUSTRAC have conducted consultation with the affected third party as outlined below, AUSTRAC are currently experiencing a very high workload which is causing us to contact a number of FOI applicants to seek 30 day extensions of time to ensure requests are managed within the legislative time period. In addition to this high workload is the complexity of the documents sought in scope of your FOI request.

If you agree to this particular extension, your request will be due on 28 January 2025, noting the weekend and public holiday period 26 January 2025 - 27 January 2025.

I look forward to your response,

Regards,

Ashley Smith | Manager, Privacy and Information Access Team
Privacy and Information Access Team

Legal and Enforcement Branch
@AUSTRAC  W: www.austrac.gov.au
OFFICIAL

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OFFICIAL
Good morning AS,

I'm hoping you have had an opportunity to consider the below correspondence. I look forward to your response as soon as possible please, thank you.

Regards,

Ashley Smith | Manager, Privacy and Information Access Team
Privacy and Information Access Team

Legal and Enforcement Branch
@AUSTRAC  W: www.austrac.gov.au

OFFICIAL

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