Identify the provider role
A remittance provider accepts customer instructions to transfer money or property to a recipient. Identify the actual service and provider role before assigning duties.
Registration and enrolment are different requirements. Apply the registration category and any relevant exception to the service.
Source: AUSTRAC: Overview; registration and incidental transfers.
Three registration categories
AUSTRAC identifies remittance network providers, network affiliates and independent remittance dealers. Each relevant category needs its own registration.
A network provider supplies its brand, products, platform or systems to affiliates. An independent dealer uses its own arrangements.
An affiliate that also provides independent services needs the relevant independent registration. An affiliate arrangement does not cover every separate activity.
Source: AUSTRAC: Types of remittance service providers.
- Network provider
Provides the platform or system and normally registers its affiliates.
- Affiliate
Uses the network arrangement. Separate independent services need their own registration.
- Independent dealer
Uses its own arrangements. Examine each relevant registration category.
Distinguish the three provider roles
These are distinct registration categories. One business can need more than one category; a network arrangement does not cover separate independent services.
Separate evidence questions. An answer to one does not settle the others.
Invented example: incomplete recipient details
In a fictional transfer, staff receive incomplete recipient details. They identify the missing information and follow the applicable policies before taking the next step.
The file records the customer instruction, evidence and response. An incomplete field alone does not settle the suspicious matter reporting question.
What the network provider does
AUSTRAC describes network duties that include affiliate registration, specified reporting and an AML/CTF program. The division of work needs clear records.
Its guidance says the network provider or affiliate can submit an SMR, depending on their written agreement. Do not infer the arrangement from a brand name.
Prepare for reporting changes carefully
Applicable IFTI reporting continues until the IVTS reporting transition date. AUSTRAC identifies 31 March 2029 or an eligible substitute date no later than 30 September 2029.
Eligibility and notice conditions apply to substitute dates. Virtual-asset transfer activity can restrict that option.
Use the transfer-report article for the reporting requirements. A future reporting transition does not suspend current AML duties.
Source: AUSTRAC: Transition to international value transfer service reporting.