• 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.

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.