A payment platform is a form of online infrastructure that supports online money transfers and serves as an electronic alternative to traditional paper methods like cheques and money orders.
The first step into the market will always be determining whether you need to obtain an Australian Financial Service Licence (“AFSL“) and then applying for the appropriate authorisations.
Depending on how a payment platform is operated, the platform will most likely be considered a Non-Cash Payment (“NCP“) facility, meaning the platform allows payments, or causes payments to be made, otherwise than by physical delivery of Australian or foreign currency in the form of notes and/or coins.
Where the platform is regulated as a non-cash payment facility, you will be required to hold an AFSL in order to operate the payment platform unless the exemption applies.
If a payment platform is operated as a wallet where customers can store funds in the wallet for the ease of making and receiving payments, the payment platform will be regulated as a NCP facility. Therefore, a business wanting to operate a wallet will be required to have an AFSL which allows them to issue a NCP facility.
Where a payment platform is designed to facilitate international payments in different currencies, it is important that the payment platform has the foreign exchange function allowing the funds to be converted into different currencies when making and receiving payments.
If you intend to operate a small business offering remittance payments, you may be eligible for an exemption where your operations meet the following criteria:
If all of the above criteria are met you may not need to apply for an AFSL, however, you will be required to register as a remitter with AUSTRAC. For more information on the remittance registration, please refer to our Remittance webpage.
Sophie Grace can assist you to determine whether your business falls within the exemption criteria listed above, please contact us for further information.
Whether you are required to have an AFSL or only operate as a remitter, you will be required to comply with the AML/CTF Act and Rules.
However, depending on the business model and the nature of platform to be provided, the transaction reporting obligations may vary. It is crucial for payment platform operators to understand their AML/CTF obligations, establish an appropriate AML/CTF compliance program, including an AML/CTF Policy and Risk Matrix, carry out staff training and conduct regular compliance reviews of its implementation of the AML/CTF compliance program.
If you are still unsure whether your proposed business requires an AFSL or AUSTRAC remittance registration, Sophie Grace can provide you with effective and practical guidance tailored to your business. Please contact us for further information.
Sophie Grace can provide you with an AML/CTF Program and can assist you to tailor it to your business’ needs. We have three different options available to suit your business and finance needs.
You can purchase template documents from our online shop. The template is an instant download and includes prompts to help you tailor the document yourself. We have template documents for:
Sign up to the Compliance Portal and receive the template AML/CTF Program Package, and obtain access to updated documents in light of any updates we make as new guidance or amended legislation is released. Choose between:
Sophie Grace can assist you to prepare the AML/CTF Program package based on your business’ specific requirements. Contact us to discuss further.
Find everything you need in relation to the AML/CTF Reforms
Sign up today for up-to-date compliance policies and regular consultation with our staff. Watch our demonstration video now!
We will get in touch as soon as possible
