Legitimate Money Remittance Providers in AustraliA

ARCPA is committed to promoting good, professional and legitimate money remittance providers in Australia. ARCPA is also committed to encouraging ethical and equitable behaviour by members through the development of industry standards and creating “level playing fields” and competitive markets. To that end and in the interest of our industry, we would like to work with the regulator and authorities to remove the illegitimate remittance providers.
 
To report a business or person who you believe to be an illegal or illegitimate remittance provider or providing services which are not registered with AUSTRAC, please complete this form:​.

To help you understand what a legal or legitimate money remittance provider consists of, please refer to the following:

• Enrolment and Registration with AUSTRAC

Businesses are required to enrol and register their business with AUSTRAC as money remittances services are part of Designated Services under the AML/CTF Act in Australia.  Please see references below. 
http://austrac.gov.au/businesses/enrolment-and-remitter-registration/enrolment-and-registration
​http://austrac.gov.au/businesses/enrolment-and-remitter-registration/remittance-sector-register

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• AML/CTF Compliance Program

Businesses will need to have an AML/CTF Compliance Program implemented prior to providing remittance services, including but not limited to:

• Collecting and verifying customer identification
• Transaction monitoring system including PEP screening
• Reporting of IFTI and TTR
• Reporting of suspicious matters
• ML/TF risk awareness training
• Record keeping

Businesses should commit the time and resource to ensure that they comply with the AML/CTF requirements in Australia. 

• Sanctions Compliance Program

Remittance service providers are required to comply with the sanctions regime in Australia and internationally by screening the names of the sender and receiver of every transaction against the sanctions lists on an automated basis. These lists require constant updates and are available through reputable vendors. 

• Representation to the Banks

Remittance service providers should be declaring to their bank about the nature of their business (e.g. Groceries and remittance services). Remittance business must not misrepresent to their banks or mislead the banks in order to hide their remittance business. Further, if a service provider is engaged to help establish a bank account for the remittance business, the arrangement should not misrepresent or mislead the bank in order for the remittance business to open or maintain a bank account.  

• Management of Customer Funds

Remittance service providers must ensure that the customers’ funds for remittance transactions are not co-mingled with other funds of the business. There needs to be a separation of the funds in order to protect the remittance customers from any form of abuse or mishandling. Remittance providers with mixed businesses should request for separate bank accounts to manage their customers’ funds and other working capital.  

• Unlicensed or unregulated remittance
  

Any form of unlicensed or unregulated remittance is not allowed. Remittance service providers must report to AUSTRAC, IFTIs, and TTR and SMR's as required. 

Businesses should not employ undocumented, anonymous and informal fund transfers that avoid having a money trail for regulators and law enforcement agencies to conduct their monitoring and supervision. There should be formal checks and balances with an audit trail for auditors and government enforcement agencies to conduct their reviews.

• Treasury and Foreign Exchange

Depending on the size and complexity of the remittance service provider, the business should implement a Treasury function to buy and sell foreign currency. The function should prohibit speculation in the local currency, prohibit foreign exchange transactions at anything other than the official rate of exchange, and conduct trades with licensed foreign exchange dealers such as the banks and foreign exchange houses. 

• ARCPA Certification Program

Remittance services providers are recommended to undergo the ARCPA Certification program to become a Certified Member. This certification is an industry accreditation program that establishes the benchmark of compliance best practice for the remittance industry in Australia. Remittance service providers who are awarded as ARCPA Certified Member, distinguishes themselves for their quality, professionalism and commitment to the highest compliance standard.