AML/CTF Compliance Framework

At IPAY, we are fully committed to upholding the highest standards of Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) regulations in accordance with Australian law. Our operations strictly comply with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act) and are regulated by the Australian Transaction Reports and Analysis Centre (AUSTRAC).

We implement robust policies and procedures designed to detect and prevent money laundering and terrorism financing, ensuring our services are not misused for illicit purposes. Our commitment to AML/CTF compliance is reflected in the following practices:

  1. Customer Due Diligence (CDD)

    To prevent financial crime, we conduct Customer Due Diligence (CDD) on all customers, which includes verifying their identity and understanding the nature of their transactions. This process ensures that we only engage with legitimate customers, mitigating the risk of financial crimes.

    Key CDD Procedures:
    • Identity Verification: We collect and verify official documentation to confirm the identity of our customers, such as government-issued identification.
    • Beneficial Ownership: For corporate clients, we identify the ultimate beneficial owners to ensure transparency and compliance with Australian regulations.
    • Risk Assessment: We assess the level of risk each customer poses, with a particular focus on high-risk customers or transactions, to determine the appropriate level of scrutiny and due diligence.
  2. Risk-Based Approach (RBA)

    We adopt a Risk-Based Approach (RBA) to evaluate and manage the risk of money laundering and terrorism financing across all our customer interactions. By analyzing factors such as the nature of transactions, geographic location, and customer profiles, we apply proportionate measures to effectively mitigate potential risks.

    • Standard Due Diligence: For low-risk customers, we apply basic CDD procedures.
    • Enhanced Due Diligence (EDD): For high-risk customers, such as politically exposed persons (PEPs) or those located in high-risk jurisdictions, we apply Enhanced Due Diligence to gather more detailed information and monitor their activities closely.
  3. Transaction Monitoring & Reporting Suspicious Activities

    We continuously monitor all transactions to detect and report suspicious activities. If any unusual or potentially illicit transactions are identified, we promptly file Suspicious Transaction Reports (STRs) with AUSTRAC.

    • Suspicious Activity Detection: We monitor customer transactions in real-time, using advanced systems designed to identify red flags indicative of money laundering or terrorism financing.
    • Reporting Obligations: Any suspicious activity is reported to AUSTRAC, in accordance with Australian regulatory requirements.
  4. Record-Keeping

    In line with AUSTRAC regulations, we retain customer records and transaction details for a minimum of seven years after the completion of the transaction or the end of the customer relationship. This ensures that all records are available for inspection by regulatory authorities or law enforcement when needed.

    • Transaction Records: All transaction details, including the identity of the parties involved, transaction amounts, and relevant dates, are securely stored for the mandated period.
    • Access to Records: We maintain a comprehensive system for record access, enabling efficient retrieval during audits or investigations.
  5. Employee Training & Awareness

    At IPAY, we prioritize the ongoing education of our employees to ensure they are well-equipped to detect suspicious activities and understand their AML/CTF obligations. Our training program includes:

    • AML/CTF Regulations: Regular training on identifying the signs of money laundering and terrorism financing.
    • Reporting Procedures: Employees are trained on how to properly report suspicious activities to AUSTRAC and comply with all legal obligations.
    • Ongoing Education: We provide continuous training to stay current with evolving regulations and emerging risks in the financial crime landscape.
  6. Independent Audits and Compliance Reviews

    To ensure the effectiveness of our AML/CTF compliance measures, we regularly conduct independent audits of our policies, systems, and controls. These audits help us identify areas for improvement, ensuring we maintain the highest standards of financial integrity.

    • Audit Frequency: Our compliance programs are audited annually by internal and external auditors to ensure ongoing adherence to regulatory requirements.
    • Continuous Improvement: Based on audit findings, we continually refine our processes and systems to enhance compliance.
  7. Reporting to AUSTRAC

    In addition to suspicious transaction reporting, we comply with other AUSTRAC requirements, including the reporting of:

    • Threshold Transactions: Transactions exceeding $10,000 AUD.
    • International Funds Transfers (IFTs): Cross-border transactions are closely monitored and reported as required.

Through these practices, IPAY remains dedicated to ensuring that we operate in full compliance with Australia’s AML/CTF laws and contribute to the global fight against financial crime.

Commitment to Financial Integrity

By adhering to these comprehensive AML/CTF measures, IPAY ensures the highest level of security and compliance, fostering trust among our customers and safeguarding the financial system from exploitation. Our compliance program supports not only Australian regulations but also contributes to maintaining global financial integrity.

To access our full AML / CTF and CDD programs, you can email us at [email protected]