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- Determine the characteristics of your remittance business
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- Payment corridors and any other jurisdictions you will deal with
- Currencies you will exchange
- Customer types
- Whether your business offers only spot FX or also forward or option contracts, or stored value products
- Whether your business relies on third party agents
- Whether you will hold stored value on behalf of customers
- Relationships with agents/ intermediaries/ correspondent banks
- Other services
- Use of agents or affiliates to deliver services
- Draw up an end-to-end funds flow diagram, showing how you and third parties will work together to deliver funds across corridors
- Confirm corporate structure: e.g. subsidiary, partnership, JV or branch office?
- Seek legal advice on whether you need an Australian Financial Services Licence (AFSL) or Purchased Payment Facility Licence (PPF).
- Prepare and lodge an AFSL application (if required)
- Design and implement an AML/CTF Program including an AML/CTF Risk Assessment
- Clarify which "designated services" you will provide, and then enrol with AUSTRAC and register on the Remittance Sector Register
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- Obtain and keep required records, including relevant police checks of key personnel
- Complete the AUSTRAC Business Profile Form
- AUSTRAC will assess your application within 90 days
- You must not provide remittance services before your AUSTRAC registration has been confirmed
- If you will outsource any functions, ensure appropriate outsourced agreements are drafted and executed
- Draft Terms and Conditions, Privacy Policy and Data Breach Policy
- Draft Financial Services Guide and Product Disclosure Statement (if an AFSL is required)
Next steps
Read our article on how to comply with your AML/CTF obligations.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
