Australia does not issue a money transfer licence in the way some countries do. It runs a registration regime. To offer remittance services you must be enrolled with AUSTRAC as a reporting entity and registered on its Remittance Sector Register, with an AML/CTF programme in place before your first customer sends a dollar. Registration is the gate. The programme, and the systems that carry it out, are what keep you operating.
This guide is for founders, compliance officers and operations leads preparing to register, or recently registered. It covers the route you choose, what to prepare, what the platform must do on day one and how to run the first 90 days. It is a practical guide, not legal advice: confirm your obligations against AUSTRAC's guidance or with an adviser before you apply. For the ongoing obligations once you are live, read our AUSTRAC compliance guide; for how to design monitoring, read AUSTRAC transaction monitoring for remittance.
Work out whether you need to register
You need to register if you provide a remittance service and your business has a connection to Australia. In practice that means accepting instructions from customers to transfer money or value to someone else, usually overseas, through a business that operates in Australia. It does not matter whether you serve customers through a shopfront, an app or agents; the obligation follows the service.
Three points cause the most confusion:
- Registration comes first. Providing a remittance service while unregistered is a serious offence. You cannot launch, take a pilot payment or "test with friends" before AUSTRAC registers you.
- Technology providers are usually not remitters. A software company that runs the platform for a registered operator, without accepting customer instructions or holding customer money, is generally not the one that registers. If it starts accepting instructions in its own name, that changes. Get advice if your structure is unusual.
- Registration is not permanent. It must be renewed every three years, and AUSTRAC can refuse, suspend, cancel or attach conditions to it. Changes to key personnel, ownership or business details must be reported.
Other regimes can apply alongside AUSTRAC, depending on what else you do: for example, holding customer balances may raise payments licensing questions, and customer data is covered by privacy law. Map these with your adviser early.
Choose your registration route
AUSTRAC registers remittance businesses in three categories, and you apply for each one that fits what you do.
| Route | Who holds the AML/CTF programme | What you control | Suits |
|---|---|---|---|
| Independent remittance dealer | You, entirely | Brand, corridors, pricing, partners, programme | Operators ready to own compliance from day one |
| Remittance network provider | You, for yourself and your affiliates | The network, its systems and its affiliates' standards | Operators running agents or other businesses under their brand and systems |
| Remittance affiliate | Mostly the network provider; you apply its procedures | Your customer relationships within the provider's rules | Businesses joining an existing network |
The independent route gives the most control and the most work: your own programme, compliance officer and reports. Joining a network as an affiliate can be quicker, because the network provider applies for your registration, but you operate within someone else's risk appetite and must later rebuild the programme in your own name. On any route, you cannot provide the service until AUSTRAC has registered you.
Decide on the end state first: if you plan to register in your own name within a year or two, choose a platform and a set of records you can carry across. Moving customers, histories and reports between systems at the same time as changing regulatory status is where launches stall.
Prepare what AUSTRAC will look at
The application asks who you are, who controls you and whether you can be trusted to run the service. Prepare these before you open the form:
- Business details. Legal entity, registered and trading addresses, the services you will offer and how you will deliver them (online, branch, agents).
- Key personnel and owners. Directors, beneficial owners and senior managers, with the identity and background information AUSTRAC asks for, including police checks. AUSTRAC assesses whether these people are suitable; a past regulatory or criminal issue disclosed late is far worse than one disclosed up front.
- Compliance officer. A named person at management level with the authority, time and knowledge to run the programme. Under the reformed regime the officer must be a fit and proper person and, where you operate through a permanent establishment in Australia, an Australian resident, and AUSTRAC must be told within 14 days of the appointment.
- Banking and settlement. How customers will pay you and how money will reach recipients. Bank account opening for remitters can take longer than registration itself, so start in parallel.
- Your AML/CTF programme in draft. You are expected to have it ready to operate from the first transfer, not written after approval.
Write an AML/CTF programme that fits your business
The 2024–2026 reforms to Australia's AML/CTF laws reshaped the programme around risk. Rather than following a fixed checklist, you assess the money laundering, terrorism financing and proliferation financing risks your business faces, then write policies that manage them, and senior management approves both. For a new remitter the programme should cover:
- A risk assessment of your customers, corridors, payment and payout methods, and delivery channels. A corridor to a country under sanctions pressure carries different risk from a domestic-heavy one, and your controls should show it.
- Customer due diligence: what you collect and verify before a customer transfers, when you do more, and how you keep it up to date.
- Transaction monitoring and sanctions screening: what you check, which thresholds apply per corridor, and who reviews what.
- Reporting: international transfer reports, threshold reports for physical cash if you take it, and suspicious matter reports.
- Governance, training and record keeping: who owns each control, how staff are trained, and how long records are kept.
- Independent evaluation of the programme, at least once every three years, and how you will review it when the business changes.
Do not copy a template or another operator's programme line by line. AUSTRAC expects a document that describes your actual business, and an examiner will test whether your systems do what the programme says.
Watch for: a programme that promises controls the platform cannot perform. If the document says transfers above a set amount wait for a person, or that everyone is re-screened when sanctions lists change, check the platform does exactly that before you launch.
Confirm what the platform must do on day one
The programme is a promise; the platform keeps it. Before the first live transfer, walk through each control below and see it work on a test transfer in your staging environment.
| Control | What must be true at launch | How to test it |
|---|---|---|
| Customer identification | No transfer completes before the customer is identified and verified to your programme's standard | Start a transfer as a new customer and confirm the ID and face check is required |
| Limits and documents | AUD limits per corridor and period are set, and the platform asks for more documents as totals grow | Send test transfers that cross each tier |
| Sanctions screening | Every sender and recipient is screened, including against the Australian sanctions list | Enter a known test name and follow the match to a decision |
| Risk rules | Risky transfers stop and wait for a person | Trigger one rule and confirm the transfer is held |
| Reporting | International transfers can be reported to AUSTRAC from your own records | Run a report on test data and reconcile it to the transfers |
| Suspicious matters | Staff know how to escalate, and the compliance officer can record and submit a report | Walk a test case from alert to decision |
| Records and access | Each person has their own account and two-step sign-in; decisions are recorded | Check a screening and a KYC decision show who decided and when |
Two settings are often missed: a fee rule for every corridor, even if the fee is zero, and the countries customers can send from, so you do not onboard people you cannot serve.
Run the first 90 days as a controlled launch
The first quarter after registration is when your programme meets real customers. Treat it as a monitored launch, not business as usual.
Days 1 to 30: prove the controls.
- Open one or two corridors, not all of them. Keep AUD limits conservative until you have seen real behaviour.
- The compliance officer reviews every held transfer and every possible sanctions match personally, and notes where the rules were too tight or too loose.
- Complete staff training before anyone handles a live customer, with sign-off by someone other than the trainee.
- Run your first international transfer report early and reconcile it to the transfers line by line, so the process is familiar before volumes grow.
Days 31 to 60: tune and document.
- Adjust limits and risk rules with a written reason for each change. An examiner will ask why a threshold moved.
- Check how many customers abandon at the identity step and fix friction, without lowering the standard your programme sets.
- Agree response times with payout partners, and how they tell you about returned or rejected payments.
Days 61 to 90: review and widen.
- Hold a formal review: alerts raised and how they were closed, suspicious matter decisions, report completeness, training status.
- Update the risk assessment with what you have learned, then decide whether to add corridors or raise limits.
- Record the review and the decisions in a form you could show AUSTRAC.
Scenario: an independent remitter's first month
The details are illustrative, not drawn from any real operator. The figures are examples, not recommended limits.
A newly registered independent remitter opens one corridor, sending AUD from Australia. Its programme sets an AUD rule: up to AUD 1,000 in a month needs a verified ID and face check; above AUD 1,000 in a month, proof of address; above AUD 5,000 over 90 days, a source-of-funds document; and any single transfer above AUD 3,000 waits for a person.
Week 1. A new customer signs up and starts a transfer of AUD 400. The ID check and selfie happen inside that first transfer, and the transfer moves on once identity is verified. Two days later she sends AUD 800, taking her monthly total to AUD 1,200; the platform asks for proof of address before the second transfer can proceed.
Week 2. A recipient's name partly matches an entry on the Australian sanctions list. The match does not block anything by itself; a person decides. The compliance officer compares date of birth and location, clears it with a written reason, and the ruling is kept so the same name is not flagged again.
Week 3. A customer sends AUD 3,400 in one transfer. It is held for review. The officer checks the customer's history and stated purpose, asks for a payslip through the app, and releases the transfer once it arrives.
Week 4. The officer runs the month's international transfer report, previews it, and sees that one transfer whose payout later failed is included, while a cancelled transfer is not. That matches the reportability rule in the programme. The completeness check confirms every in-scope transfer is present, and the report is exported for lodgement.
What the scenario shows: each control in the programme happened on the platform, at the moment it was needed, and left a record. That is the standard to aim for in the first month, before volume makes gaps expensive.
Avoid the mistakes that delay or endanger registration
- Launching before registration. Even a small pilot is a remittance service.
- A compliance officer in name only. A director with no time or a part-time contractor who never sees the alerts does not meet expectations.
- Banking left until last. Without accounts to collect and settle, registration alone does not let you trade.
- A programme that does not match the platform. Thresholds, document tiers and review steps in the document must be the ones configured.
- No reconciliation of reports. Reporting from spreadsheets assembled by hand invites missing transfers.
- Not reporting changes. New directors, owners or addresses must be notified to AUSTRAC.
Doing it with RemitSo
RemitSo is a white label remittance platform: customer apps in your brand and an admin panel your team runs the business from. For a new Australian remitter, it gives you the day-one controls above, configured to your programme. See the admin features.
- ID check, selfie and live face check inside the first transfer, with a reviewer able to override and the reason kept: customers are verified before money moves, without a long sign-up form.
- AML rules per currency, including AUD, with windows from every transaction to one year and document tiers: the limits and documents in your programme are the ones the platform enforces.
- Sanctions screening against 8 lists loaded every night, including the Australian DFAT list, with everyone re-screened when lists change: you can show who was checked against what.
- 46 risk indicators combined into your own rules: risky transfers wait for a person and everything else flows on its own.
- AUSTRAC IFTI-E reporting from the platform's own transaction record, in Excel or CSV, with a preview and a check that every in-scope transfer is included: reports reconcile back to transfers.
- Suspicious activity reports generated, managed and submitted from the console: escalations stay with the transfer and customer they relate to.
- Staff training by department with sign-off, an optional add-on, where nobody signs off their own: proof that people were trained before they touched live customers.
- Your own instance in a dedicated AWS account in your region, live in 3 to 4 weeks on white label: the platform can be ready while registration and banking complete (pricing).
Your team still writes and owns the programme, registers with AUSTRAC, opens banking, decides on alerts and lodges reports. See RemitSo for startups, getting started, or book a demo.
Sources
- AUSTRAC: Register with us as a remittance or virtual asset service provider
- AUSTRAC: Unregistered remittance service providers
- AUSTRAC: Renew your registration
- AUSTRAC: Preparing for the changes as a current reporting entity
- AUSTRAC: AML/CTF compliance officer
- AUSTRAC: Conduct an independent evaluation
- AUSTRAC: International funds transfer reports
- AUSTRAC: Threshold transaction reports
- AUSTRAC: Suspicious matter reports
- AUSTRAC: Record keeping checklist
Checked October 2026. Regulations change; confirm current requirements with the regulator or your adviser.
Frequently asked questions
Is there a money transfer licence in Australia?
Not as a separate licence. Remittance businesses enrol with AUSTRAC and register as a remittance provider, and must run an AML/CTF programme. Other licences may apply depending on what else you offer, so check with an adviser.
Can we start taking customers while our registration is being assessed?
No. You must be registered before you provide remittance services. An affiliate of a remittance network is registered through its network provider, but it also cannot start until AUSTRAC has registered it.
Which registration category should a new online remitter choose?
Most independent online businesses register as an independent remittance dealer. If you plan to run agents or other businesses under your brand and systems, the network provider category may fit. Confirm the right category with AUSTRAC guidance or an adviser.
Does the platform provider need to register with AUSTRAC?
Generally not, if it only supplies technology and does not accept customer instructions or hold customer money. The registered operator remains responsible for its own programme and reports.
What should we review at the end of the first 90 days?
Alerts raised and how they were closed, suspicious matter decisions, report completeness, training status and whether limits and rules need adjusting, then update the risk assessment and record the decisions.