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

☐ 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.