Procurement compliance considerations

Currently waiting for a response from Australian Transaction Reports and Analysis Centre, they should respond promptly and normally no later than (details).

Dear Australian Transaction Reports and Analysis Centre,

This is a Freedom of Information Request under the Freedom of Information Act 1982. 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.

Yours faithfully,
AS

INFO_ACCESS, Australian Transaction Reports and Analysis Centre

This is an automated response to your email which has been received by the
Privacy and Information Access team at AUSTRAC. A team member will be in
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INFO_ACCESS, Australian Transaction Reports and Analysis Centre

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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