AUSTRAC Money Remitter Registration Solutions | AML/CTF Solutions | AUSTRAC Money Remitter Registration Application Management | Post-licensing Risk and Compliance Support

We offer a comprehensive set of solutions to help you obtain and maintain an Australian Money Remitter registration with the Australian Transaction Reports and Analysis Centre (AUSTRAC), tailored to:

• Your business goals and objectives
• Your client demographics
• Your countries of operation
• The size of your business
• The available human and technology resources
• Your risk appetite
• Your governance structure
• The products that you offer
• AUSTRAC regulated money remitters' obligations covering risk and compliance management under financial laws and regulations, the applicable financial licensing requirements, AML/CFT laws, privacy laws, consumer protection laws, and more

We have designed our regulatory licensing solutions to help you navigate the complexities of the Australian money remitter regulatory regime in a commercially oriented and goal-focused manner, providing effective support for all stages of the Australian money remitter licensing process, including but not limited to the following aspects:

• AUSTRAC Money Remitter Registration Guidance: Advising on a wide range of aspects associated with AUSTRAC money remitter registration as it relates to your specific situation
• Pre-licensing assessment: Covering compliance gap analysis as well as risk and compliance assessment
• Pre-licensing support:
• Drafting the necessary policies and procedures to help you comply with the AUSTRAC money remitter registration conditions and AML/CTF regulations
• Developing internal controls to help you meet your obligations under the Australian money remitter regulatory regime
• AUSTRAC Money Remitter Registration Application Support: Covering the entire licensing process
• Post-licensing Support: Covering
• Ongoing compliance advice
• Comprehensive second-line risk and compliance support, including leading the implementation of your risk management framework (RMF), compliance management framework (CMF), compliance monitoring program (CMP), compliance calendar and checklist, ongoing risk assessments, internal and external reporting, outsourced providers' management, and more
• AML/CFT advice
• AML/CFT compliance management
• Compliance assurance solutions, including compliance assurance program (CAP) development, implementation, and internal control testing

 

 

Service Coverage

This page is about Australian Money Remitter registration. In Australia, any entity that provides a money remittance service - including international funds transfer, inward/outward remittance, and digital currency exchange that facilitates remittances - must be registered with AUSTRAC under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act).

Money remitters are classified as providers of a “designated service” and are subject to obligations including:

• maintaining a compliant AML/CTF program,
• customer due diligence (CDD/KYC),
• transaction monitoring,
• suspicious matter reporting (SMRs),
• threshold transaction reporting (TTRs), and
• ongoing enrolment and reporting requirements.

Depending on their business model, remitters may also require additional authorisations - for example, an AFSL where remittance is combined with financial product services, or ACCC compliance where consumer protection issues arise. We offer comprehensive support for a wide range of AUSTRAC money remitter registration applications tailored to meet the specific needs of the following businesses:

• Peer-to-Peer Payment Services
• Domestic Money Remitters
• Consumer Money Remitters
• Commercial Money Remitters
• Mobile Payment Providers
• Cryptocurrency Remittance Platforms
• E-Wallet Providers
• Prepaid Card Issuers
• Remittance Service Providers
• Foreign Exchange Dealers
• International Money Remitters
• Digital Money Remitters

You can find more information about our AUSTRAC money remitter registration solutions below.

 

 

Australian Money Remitter Licensing Preparation

Pre-licensing Compliance Assurance

Our AUSTRAC money remitter registration solutions cover the following focus areas:

• Compliance Goals Analysis: We review your business-specific goals and resources against the suitability criteria for an AUSTRAC money remitter registration
• Initial Consultation: We provide guidance on potential risk and compliance issues that may arise during the Australian money remitter registration process
• Choosing the Right Jurisdiction: We assist in evaluating regulatory, risk, and compliance environments to determine the most suitable jurisdictions for your AUSTRAC money remitter registration, tailored to suit your:

• business objectives,
• operational capacity,
• client base,
• markets of operations,
• and other relevant factors

• Gap Analysis: We identify gaps between your existing operations and regulatory requirements and help you align them in a commercially oriented manner
• AUSTRAC Money Remitter Registration Application Plan: We help you establish a roadmap to effectively meet the AUSTRAC money remitter registration requirements

 

 

AUSTRAC Money Remitter Registration Guidance

Selecting the right compliance model is crucial not only for navigating the licensing process but also for maintaining ongoing compliance and avoiding potential breaches. Our Australian money remitter licensing solution covers:

• Compliance Model Selection: To help you best comply with the Australian money remitter regulatory regime and related risk and compliance obligations.
• Corporate Governance Model Selection: We offer practical guidance on establishing effective corporate governance practices that support your risk and compliance oversight.
• Operations Model Advisory: We advise you on optimising your operational and governance models to help you efficiently comply with the Australian money remitter regulatory regime and other applicable AUSTRAC regulated money remitters’ obligations, keeping in mind your specific circumstances, available resources and business goals.

 

AUSTRAC Money Remitter Registration And Entering Regulated Environment

We help businesses transition from an unregulated environment to operating under the Australian money remitter regulatory regime, helping them meet their obligations as an AUSTRAC money remitter registration holder.

We also assist already regulated businesses in aligning their existing risk and compliance management structures with the Australian money remitter regulatory regime requirements.

Our focus areas for this service include:

• New businesses
• Existing money remmitance providers operating in unregulated markets
• Regulated Australian money remitters expanding into foreign jurisdictions
• Financial institutions and/or service providers with established risk and compliance frameworks seeking to offer regulated money transfer services as a new product.

 

Multi-Jurisdictional Compliance

With years of experience managing risk and compliance obligations for businesses operating under multiple financial licences across various jurisdictions, we help businesses remain compliant with the regulated money remitters’ obligations globally.

 

 

AUSTRAC Money Remitter Registration Application

We assist with your licence application through ongoing engagement in the Australian money remitter licensing process:

• Document Compilation and Review: We compile and review all required supporting documents to support your AUSTRAC money remitter registration application.
• Application Form Completion: We help you complete the forms so that all material information is accurate and complete.
• Pre-Submission Review: We can arrange a pre-submission review session with key stakeholders to ensure all parts of your application are understood and agreed upon. This session aligns application details with the actual situation, removing ambiguity.
• Regulatory Liaison: We manage the end-to-end submission process, maintaining clear and effective communication channels throughout the regulated Australian money remitter regulatory process.
• Timeline Management: We closely monitor and adhere to all necessary deadlines, providing timely updates and adjustments to keep the application process on track.

 

Resolving AUSTRAC Money Remitter Registration Issues

Having competent compliance advisors is crucial when licensing issues arise. Therefore, our AUSTRAC money remitter registration solutions include a range of services to address and resolve these issues effectively:

• Remediation Solutions for AUSTRAC Money Remitter Registration Applicants: We address and remediate risk and compliance issues identified by regulators, helping your operations align with the Australian money remitter regulatory regime requirements.
• Specific Licence Conditions Compliance: We can help you manage additional conditions imposed on your AUSTRAC money remitter registration, developing a tailored action plan to maintain compliance and facilitate the eventual removal of these conditions with minimal disruption to your business operations.
• Licensing Issues Handling: We address common licensing issues encountered during the Australian money remitter licensing process, providing you with solutions to navigate and resolve these challenges efficiently.
• Further Information: You can visit our Compliance Remediation Solutions page for more information.

 

Post-Licensing Support

We offer a full range of ongoing risk and compliance solutions for regulated Australian money remitters. Our services include, but are not limited to:

Ongoing Risk and Regulatory Compliance

• AUSTRAC Regulated Money Remitters’ Obligations Guidance: We can advise your risk, compliance, management and other teams on meeting the requirements of the Australian money remitter regulatory regime and other regulatory compliance obligations. You can visit our Compliance Advisory page for more information.
• Regulatory Risk and Compliance Management: We provide dedicated compliance managers to manage your overall compliance. For more information, visit our global Compliance Management Solutions page for Money Transfer Businesses.
• Compliance Assurance Solutions: As part of our compliance assurance solutions, we offer:
• Compliance Assurance Program (CAP) development and testing options
• Internal Controls Design option
• Internal Controls Testing option
• Internal AML/CFT Review option
• Statutory AML/CFT Audit option
• Compliance Training Solutions: We offer training programs to different teams on complying with:

• AUSTRAC regulated money remitters’ obligations for risk and regulatory compliance management. You can visit our Compliance Training page for more information.
• Australian money remitters’ AML/CFT obligations and operational best practices for fraud prevention. You can visit our AML/CFT Training page for more information.

• Crisis Management Planning: We can develop proactive strategies to manage potential compliance crises effectively.
• Anti-Money Laundering (AML) and Counter Terrorist Financing Solutions: We provide a full range of AML/CTF solutions for Australian money remitters. For more information, visit our Specialised AML/CFT Solutions page for Money Transfer Businesses.
• Advanced Compliance Technologies: We can assist you with selecting and integrating advanced technology solutions, such as compliance automation tools and regulatory technology (RegTech), to streamline compliance processes without disrupting operations.
• Risk and Compliance Framework Adjustments: Including adjustments to risk management frameworks (RMFs), compliance monitoring programs (CMPs), compliance management frameworks (CMFs), and other core procedures and policies to align them with:
• new business goals
• regulatory changes
• changes in your operations
• evolving market conditions
• changes in stakeholders’ risk appetites (your banking partners, insurance companies, liquidity providers, etc.).

 

 

Risk and Compliance Obligations for AUSTRAC Money Remitter Registration Holders

AUSTRAC money remitter registration holders are subject to various obligations set out in applicable laws and regulations. They are also expected to uphold standards for their conduct and internal operations, as outlined in regulatory guidance or accepted industry practices.

We can help you address these obligations and expectations through comprehensive support in the different areas. The list below is not exhaustive:

Money Remitter’s Licence and Regulatory Compliance Obligations

• Compliance Management Systems: We can help you establish effective compliance programs, compliance monitoring plans, controls testing methodologies, compliance calendars and more (as required under the ASIC RG 104  and RG 185 (NCP)).
• Risk Management Frameworks: We can help you develop comprehensive risk management frameworks to fulfil AUSTRAC regulated money remitters’ obligations for identifying, assessing, and mitigating operational, regulatory, strategic, financial and other types of risks (as required under the ASIC RG 104).
• Policy and Procedure Development: We can help you draft and implement policies and procedures aligned with the money remitters’ licensing requirements. (as required under the Corporations Act 2001).
• Compliance Monitoring Plans: We can oversee the execution of your CMPs, covering ongoing monitoring of your compliance obligations under the money remitters’ licensing regime.
• Internal Control Testing and Compliance Assurance: We can conduct internal reviews and audits of your controls to test their effectiveness and compliance with the applicable regulatory standards.
• Financial Auditing Standards: We can assist in establishing procedures to help you comply with the audit and assurance requirements under the money remitters’ licensing regime.
• (as required under the Corporations Act and ASIC guidance, see: ASIC FS70 form).
• Digital Payment Token Services: If your business supports digital assets or stablecoin-based transfers, we can help you develop controls to meet AML/CFT requirements and applicable licensing conditions for digital payment token services, including transaction monitoring, wallet screening, and Travel Rule compliance (as required under the Corporations Act and ASIC guidance).
• Client Money Reporting Obligations: We can help you meet your reporting and reconciliation obligations for client money under the money remitters’ licensing regime, including requirements to prepare and submit client money reports and perform daily and monthly reconciliations (as required under Corporations Act 2001 and ASIC Client Money Reporting Rules).

 

Money Remitter’s Licence and Operational Oversight Obligations

• Oversight of Outsourcing: We can establish a set of effective controls to comply with AUSTRAC regulated money remitters’ obligations for overseeing outsourced services, also covering related obligations under AML/CFT compliance, ISO requirements, and more.
• Structures for Governance: We can help you establish effective governance structures to comply with AUSTRAC regulated money remitters’ obligations and develop an effective approach to overseeing your risk exposure and compliance status across different functions of your business.
• Senior Management Accountability: We can help you comply with AUSTRAC regulated money remitters’ obligations for senior management and key staff conduct and competence (as required under ASIC RG 105).
• Maintaining Operational Resilience: We assist in developing continuity plans to meet AUSTRAC regulated money remitters’ obligations for operational resilience and transaction flow continuity, helping critical business services withstand disruptions.
• Managing Technology Risks: We provide guidance on technology risk management obligations under the money remitters’ licensing regime.

 

Money Remitter’s Licence and Market Integrity/Transparency Requirements

• Principles for Fair Treatment: We can help you implement controls to comply with expectations that cover adherence to principles of fair treatment and transparent communications with clients.
• Standards for Conduct and Disclosure: We can help you comply with money remitters’ licensing standards for conduct and disclosure.
• Protection of Client Assets: We can help you comply with money remitters' licensing obligations to protect and segregate client assets (as required under the ASIC Client Money Reporting Rules 2017).
• Resolution of Disputes: We can help you establish effective mechanisms for dispute resolution and complaints management, particularly for retail clients (as required under the RG 271 Internal Dispute Resolution).

 

Money Remitter’s Licence and Resource Management Obligations

We can help you comply with the following requirements of the money remitters’ licensing regime:

• Adequacy of Resources: Covering financial, technological, human and other resources.
• Responsible Manager Competence: We can help you nominate, assess, and maintain suitable Responsible Managers in accordance with the money remitters’ licensing requirements, covering their qualifications, experience, and ongoing competence. (as required under Corporations Act 2001 and ASIC Regulatory Guide 105)/
• Our focus areas include:

• Assessment and Gap Analysis: We can help you evaluate the adequacy of your financial, technological, and human resources against the requirements of the licensing regime.
• Resource Allocation Plans: We can help you develop strategies to optimise resource allocation, covering sufficient capacity for compliance, trading, operations, banking, customer support and other functions and departments.
• Technological Solutions: We can recommend and implement RegTech tools to streamline compliance processes, such as transaction monitoring, reporting, and audit trails.
• Key Personnel Assessment: We can help you assess the skills, qualifications, and experience of key personnel to identify areas for improvement.
• Training and Development Programs: We can design and deliver targeted compliance training programs to upskill personnel in compliance, risk management, and money transfer regulations.
• Representative Vetting: We can help establish a framework for assessing the competence and suitability of advisors and representatives before appointment.
• Compliance Monitoring: We can help develop controls to monitor representatives' adherence to conduct and disclosure obligations.
• Ongoing Training: We can help you create a framework to support continuous education for advisors and representatives on licensing obligations, market integrity, and client interaction standards.

• Regulator Liaison: We can act as an intermediary with regulators to address queries and help you demonstrate compliance with resourcing obligations.

 

Money Remitter’s Licence and Reporting

• Regulatory Reporting: We can help you prepare and submit periodic and ad-hoc reports covering:
  • Australian money remitters’ AML/CFT obligations (SMRs, cross-border transaction reports, cash transaction reports, and other reporting obligations (as required under the relevant AUSTRAC guidance).
• Compliance Documentation: We can help you develop and maintain the necessary documentation to meet record-keeping obligations under various laws and regulations.
• Audit Readiness: We can prepare you for audits and reviews to demonstrate compliance with regulatory requirements, provisions of the money remitters' licensing regime, applicable operational standards, and more.

 

Related Services

We assist in obtaining AUSTRAC money remitter registration equivalents in the following jurisdictions:

• United Kingdom: For more information on the UK equivalent of an AUSTRAC money remitter registration, the FCA payment institution authorisation, you can visit our FCA Payment Institution Authorisation page.
• New Zealand: For more information on the New Zealand equivalent of an AUSTRAC money remitter registration, the DIA money remitter registration, you can visit our DIA Money Remitter Registration page.
• United States: For more information on the United States equivalent of an AUSTRAC money remitter registration, the money transmitter license, you can visit our US Money Transmitter Licence page.
• Singapore: For more information on the Singaporean equivalent of an AUSTRAC money remitter registration, the SPI licence, you can visit our Singaporean SPI Licence page.
• Prominent Financial Centres and Offshore Tax Havens: We also offer licensing solutions for money remittance businesses in the prominent financial centres and offshore tax havens, including:

• Seychelles
• Cayman Islands
• British Virgin Islands (BVI)
• Belize
• Mauritius
• Gibraltar