There are a number of ongoing requirement and obligations which remittance and Money Transfer Providers face when running their businesses.  We have summarised some of the requirements for running your remittance business in a compliant manner below including:

  • What is a Remitter?
  • Do I need to enrol and/or register my business with AUSTRAC?
  • How to enrol and/or Register my Remittance business with AUSTRAC?
  • Compliance obligations.

What is a Remitter and/or Money Transfer Provider?

A remitter or money transfer provider is a person or business involved in the act of transferring, sending and/or receiving money on behalf of others. A remitter or money transfer provider can provide services to clients in any of the following capacities:

  1. Independent Remittance Dealer – Businesses that provide remittance services to customers using their own systems and processes, independent of a remittance network;
  2. Remittance Network Providers – Organisations that operates a network of remittance affiliates by providing the systems and services that enable its affiliates to provide remittance services
  3. An Affiliate of a Remittance Network Provider – Businesses that provide remittance services to customers as part of a remittance network facilitated by a remittance network provider.

Do I need to Enrol and/or Register my Remittance Business with AUSTRAC?

It is mandatory for all businesses who satisfy one of the ‘geographical link’ tests and provide remittance services to be enrolled with AUSTRAC as a Reporting Entity and register with AUSTRAC as a remitter.

The three ‘geographical link’ tests are as follows:

  1. The remittance service is provided to clients at or through a permanent establishment of your business in Australia; OR
  2. Your business is a resident of Australia and the remittance service is provided at or through a permanent establishment of the business in a foreign country; OR
  3. Your business is a subsidiary of a company that is a resident of Australia and the remittance service is provided at or through a permanent establishment of the subsidiary in a foreign country.

Once an entity has determined that they have met one of these tests; they are then required to determine the type of registration required.

Remitters are required to apply for registration with AUSTRAC as either an independent remittance dealer, remittance network provider or an affiliate of a remittance network provider.

Remitters must apply to appear on AUSTRAC’s Remittance Sector Register.  Under the AML/CTF Act it is an offence to provide remittance services if an individual or business is not registered with AUSTRAC.

Registration with AUSTRAC is issued for a set period and registration must be reapplied for every three years.

How to Enrol and/or Register your Remittance Business with AUSTRAC?

To apply for enrolment and/or registration with AUSTRAC you must complete the AUSTRAC Business Profile Form available on AUSTRAC’s website.

If you require assistance with enrolling/registering your business with AUSTRAC please contact us.

Ongoing Obligations

Once you have successfully obtained enrolment/registration with AUSTRAC you will be required to meet ongoing compliance obligations. These obligations include:

  • Notifying AUSTRAC of any changes or updates to your AUSTRAC enrolment and/or registration;
  • Conducting regular compliance reviews;
  • Reporting various transactions to AUSTRAC including International Funds Transfer Instructions (IFTIs), Suspicious Matter Reports (SMRs) and Threshold Transaction Reports (TTRs); and
  • Complying with Anti-Money Laundering and Counter-Terrorism Financing regulations, including maintaining an AML/CTF Program.

Sophie Grace can provide you with appropriate compliance solutions for your remittance business, including implementing an AML/CTF Program. Please contact us directly for more information.