Don't get on the wrong side of AUSTRAC
Is your remittance business meeting the AML/CTF rules that applied from 31 March 2026?
In short
Remittance and money transfer businesses in Australia must be registered with AUSTRAC before they operate and renew that registration every three years. You need a documented AML/CTF program, customer identification, transaction monitoring, threshold and suspicious matter reporting, and, since the 31 March 2026 reforms, an updated risk assessment and policies that reflect the new rules.
These reforms will pose a significant challenge to current reporting entities in the remittance industry. We have a deep understanding of what is required for a current remittance business to become compliant from 31 March 2026.
International value transfers will be a challenge to implement.
Why are remitters classed as high risk?
AUSTRAC places remittance providers, money service businesses and foreign exchange houses high on its watch list. We know because we've helped many companies - whether they're large, small, international or local - defend their Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Program and processes against AUSTRAC.
But the best way to avoid getting on the wrong side of AUSTRAC is to make sure that your AML/CTF Program is watertight.
What does a robust remittance AML/CTF program look like?
If your business:
- Transfers money or something of value for, or on behalf of a customer
- Trades accounts for customers in foreign exchange
- Changes money or other currency
Then you must meet your obligations under the AML/CTF laws.
Why Remittance Providers are Considered High Risk by AUSTRAC:
- Typically have a large number of transactions
- Operate cross borders in high volumes
- May have many transactions that are undertaken through intermediaries
What is the first step? AUSTRAC registration
The first step to putting in place a robust AML/CTF Program is to conduct an AML/CTF Risk Assessment. This helps you identify your risks and determine how to mitigate them.
Once your ML/TF Risk Assessment is complete, you can then put in place or review your existing AML/CTF Program.
What should your AML/CTF program cover?
Identify Risks
Identify what money laundering and terrorism financing risks your business faces
Document Procedures
Document your policies and procedures to mitigate those risks
Implement Controls
Put in place controls to manage those risks
Which parts of the program does AUSTRAC check first?
Know Your Customer (KYC) / Customer Due Diligence
These make sure that you have verified who your customer is and can be either manual or electronic to suit your business model.
Threshold Transaction and Suspicious Matter Identification
Processes to identify critical threshold transactions and suspicious matters. You will also need to complete Threshold Transaction Reports, Suspicious Matter Reports and International Funds Transfer Instructions and submit these to AUSTRAC.
Independent Review
Completing an Independent Review of your AML/CTF Program.
How can AML experts help your remittance business?
Whether you're just setting up your AML/CTF Program or AUSTRAC is already knocking on your door, we can help you. We have worked with many remittance and foreign exchange businesses so we understand how differently you can structure your business and how your business model affects your AML/CTF risks.
We have helped:
And we can help you:
- Conduct a ML/TF Risk Assessment
- Develop your AML/CTF Program
- Put in place electronic verification processes to Know Your Customer
- Conduct an Independent Review of your AML/CTF Program
- Defend you against AUSTRAC
Ready to ensure your compliance?
Don't wait until it's too late. Get started with your AML/CTF Program today.
Complete AML/CTF Compliance FormGood to know
Remittance AML/CTF questions answered
Registration, reporting, reviews and the 2026 reforms, explained for money transfer businesses.
Do I need to register with AUSTRAC before I start a remittance business?
Yes. Providing a remittance service without being on the Remittance Sector Register is an offence. Independent remitters, remittance network providers and their affiliates each have their own registration category. AUSTRAC assesses the fit-and-proper status of key personnel, your AML/CTF program and your business model before approving registration, and you must renew every three years and notify changes such as new directors or premises within 14 days.
What changed for remitters under the 2026 AML/CTF reforms?
The amended Act, which started applying to existing reporting entities on 31 March 2026, replaced the Part A / Part B program structure with an ML/TF risk assessment plus AML/CTF policies, tightened customer due diligence and travel-rule (payer and payee information) requirements for value transfers, and updated the obligations around correspondent-style relationships. Programs written under the old rules need to be re-written and re-approved, not just re-dated.
Which reports does a remittance company have to lodge?
International funds transfer instructions for every transfer into or out of Australia, within 10 business days; threshold transaction reports for physical cash of $10,000 or more, within 10 business days; suspicious matter reports within three business days, or 24 hours for suspected terrorism financing; and an annual compliance report to AUSTRAC. Reports are lodged through AUSTRAC Online, and many remitters automate transfer reporting from their platform.
How do I verify customers who send money overseas?
Collect and verify the sender's full name, date of birth and residential address from reliable documents or electronic data before the first transfer, apply higher checks for high-risk countries, politically exposed persons and unusual patterns, record beneficiary details, and keep monitoring the relationship. Occasional low-value customers still need identification; the threshold exemptions that apply to some sectors do not apply to remittance.
What is an independent review and how often is it required?
An independent review tests whether your AML/CTF program complies with the Act and Rules and is actually being followed. It must be done by someone independent of the compliance function, at least every three years or sooner if your risk changes. AUSTRAC frequently asks for the latest review during a compliance assessment or registration renewal. SNS Accounting performs independent reviews for remitters that we do not otherwise advise.
How can SNS Accounting help my money transfer business?
We prepare or update your registration application, write the ML/TF risk assessment and AML/CTF policies to the 2026 standard, design customer due diligence and monitoring procedures that work with your software, train staff and compliance officers, run independent reviews for remitters we do not otherwise advise, and support you through AUSTRAC assessments. We also look after the business's tax, BAS and bookkeeping. This page is general information, not legal advice.