FACT SHEET: How to set up a Money Remitter (also known as a Money Transfer Operator or Payment Services Provider) Checklist

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☐ Determine the characteristics of your remittance business

  • 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

  • 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.

You can also watch our expert interview with Senior Associate, Naomi Fink, on what you need to know about AML/CTF by signing up to the HN Hub for free.