REMITTANCE & PAYMENTS · REFORMED OBLIGATIONS
AML/CTF compliance for remittance and payment providers
Remittance has been one of the most closely supervised sectors in the regime for years. The reforms rebuilt the program and CDD framework underneath you, and the reporting transition is still ahead.
Already regulated? The regime still changed.
The reforms did not just add new sectors. From 31 March 2026 the program structure, customer due diligence framework and governance obligations changed for every existing reporting entity, and independent reviews of Part A became independent evaluations of the whole program. A program that was compliant in February needed rebuilding, not refreshing.
- 31 March 2026Reformed obligations begin
- 30 May 2026AML/CTF compliance officer notified to AUSTRAC
- 1 July 2026Transitional CDD policies had to be documented
- 31 March 2029IFTI reporting transitions to IVTS reporting; ACIP transitional period ends
Are you captured?
Remittance is different from most sectors in one important way: you must be registered on the Remittance Sector Register, not merely enrolled. Registration can be refused, suspended or cancelled, which makes program quality a licence-to-operate issue rather than a compliance overhead.
Likely captured
- Operating as a remittance network provider
- Operating as a remittance affiliate of a network
- Operating as an independent remittance dealer
- Accepting money or property for transfer to a beneficiary
- Making money or property available to a beneficiary in Australia on instruction from overseas
- Payment and money transfer services that involve a transfer of value
Generally outside scope
- Pure technology or software supply to a remitter, with no transfer of value
- Foreign exchange information services with no transaction
- Acting solely as an introducer with no handling of funds
Capture depends on the designated services you provide — not on your profession, your licence or your job title.
What you need in place
Enrol and register with AUSTRAC
Every reporting entity has to be on the register. Enrolment is the entry point for everything else, including how your evaluation timing is set.
Appoint an AML/CTF compliance officer
A named person with the authority, seniority and time to run the program — and AUSTRAC has to be notified of the appointment.
Write an ML/TF risk assessment
Covering your customers, the designated services you provide, your delivery channels and the jurisdictions you deal with, with the reasoning visible.
Document your AML/CTF policies
Policies, procedures, systems and controls that follow from the risk assessment, approved by a senior manager rather than filed unread.
Run initial customer due diligence
Identify and verify your customer before you provide the designated service, at a depth that matches the risk you have assessed.
Screen for sanctions, PEPs and adverse media
Screening at onboarding and again over the life of the relationship, with the result recorded either way.
Trace beneficial ownership
Where the customer is a company, trust or other arrangement, identify who ultimately owns or controls it — and show how you got there.
Keep ongoing customer due diligence running
Monitoring is not an onboarding task. Relationships have to be reviewed and re-screened as risk and circumstances change.
Report suspicious matters
Submit suspicious matter reports within the required timeframes, plus threshold transaction reports where they apply to you.
Keep records
Generally seven years, with the retention clock starting at different points depending on the record type.
Train your people
Risk-appropriate AML/CTF training for staff, refreshed over time and delivered to new starters as they join.
Have the program independently evaluated
An independent evaluation of the whole program on the cycle your policies set, with findings tracked to closure.
Maintain your registration, not just your enrolment
Remittance providers must be registered on the Remittance Sector Register. Registration carries conditions and can be suspended or cancelled where ML/TF risks are unacceptably high.
Keep reporting IFTIs until your IVTS transition date
The obligation to report international value transfer services is deferred until your IVTS reporting transition date. Until then you continue reporting international funds transfer instructions under the pre-reform framework.
Work out whether you can nominate a substitute IVTS transition date
A substitute date is only available if you gave at least one IFTI report before 31 March 2026, and must fall between 31 March 2029 and 30 September 2029.
See the evidence, not just the promise.
How True Comply helps
Customer verification built for volume
Fast identity verification and screening that keeps pace with transaction-driven onboarding.
Sanctions screening you can evidence
Every check, hit and clearance recorded with the reasoning, which is what a supervisor asks for.
Agent and affiliate oversight
Visibility across the network, so a network provider can see how each affiliate is actually performing.
Ongoing monitoring for the whole customer base
$1 per person per month, at every tier.
Program rebuilt for the reformed framework
Not a patched version of a pre-reform program.
Senior advisory on registration risk
Someone experienced to work with when registration conditions or supervisory attention are in play.
Free to start. $1 per person per month for ongoing monitoring.
Start with your first checks at no cost, then keep your whole client book monitored for a dollar a person a month.
Questions, answered.
Related insights
- Getting compliant
Your AML/CTF obligations, in plain English
6 min read
- How to
How to run customer due diligence that stands up
6 min read
- Assurance
Your first independent evaluation: what AUSTRAC actually expects
6 min read
- Getting compliant
Have you already hit 'set and forget' on your AML program?
5 min read
Compliance you can prove.
Tell us where you're at and we'll help you work out what applies to your business.
No jargon, no obligation.