Update: The AML Amendment Act 2024 passed both houses in the rush of bills passed last week.

Does a liquidator act for the company?

Under proposed amendments for the AML Act, a designated service to which the Act will apply is (paraphrased as best I can):

Receiving, holding and controlling or managing a person’s money as part of assisting the person with a transaction in the course of carrying on a business (except for payment for goods and services by the business).

Liquidators’ often make payments in the course of carrying on a business. Does the liquidator ‘receive, hold or manage’ money for or to assist a person (the company they are appointed to), or, as an officer of the company do they hold money in their own right? The former would be subject to the AML reporting and the latter would not.

Is this different for a receiver and manager?