AML/CTF POLICY FOR INSTANT EXCHANGE PTY LTD
Instant Exchange Pty Ltd, located at 2/23 Foster Street, Surry Hills, NSW 2010, offers remittance services to its customers. The company is committed to complying with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act) and the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2017 (AML/CTF Act), AML/CTF Financing Rules 2007, Anti-Money Laundering and Counter-Terrorism Financing Rules Amendment Instrument 2018 (No. 1), and other rules and regulations issued thereunder. This policy outlines Instant Exchange's commitment to implementing an effective AML/CTF compliance program.
The primary purpose of Part A of the AML/CTF program for Instant Exchange Pty Ltd is to enable the company to:
a) Identify significant changes in the risk associated with money laundering or terrorism financing it faces. b) Recognize and manage changes in ML/TF risks for the purposes of its Part A and Part B programs. c) Assess the ML/TF risk posed by all new designated services before introducing them to the market, all new methods of designated service delivery before adopting them, and all new or developing technologies used to provide a designated service before adopting them. d) Determine the appropriate level of employee due diligence to apply to its employees, agents, and consultants who carry out functions connected with the designated services and who are in a position to facilitate an ML/TF offense. e) Design a staff ML/TF risk awareness training program, considering the ML/TF risks the company might reasonably face, and determine the frequency and extent of that training.
By accepting these terms and conditions, customers give consent for Instant Exchange Pty Ltd to disclose their name, address, and date of birth to Australia Post and, from there, to a credit reporting body for identity verification purposes under the Anti-Money Laundering and Counter-Terrorism Act 2006.
A.1 How We Have Organised:
A.1.0 Organization Chart/Governance Structure:
Instant Exchange Pty Ltd operates under the control of the management, with internal checks to minimize the risk of Anti-Money Laundering/Terrorist Financing. The company conducts annual internal systems and process audits, with external checks conducted by Sunrise Accounting Pty Ltd.
A.1.1 How We Operate and Our Business:
Name of Business: Instant Exchange Pty Ltd The company estimates an average of 50 remittance transactions per week, with an average transaction value of approximately $500. Instant Exchange offers remittance services only and does not provide other services covered by the AML/CTF Act.
A.1.2 Customers and Services:
Instant Exchange serves various customers, including individuals, locals, internet customers, students, and non-individual customers (sole traders, partnerships, and companies). The company prioritizes the identification and verification of individual customers and offers remittance services mainly to Nepal through registered entities with the Government of Nepal.
A.1.3 Services and Method of Delivery:
Instant Exchange provides outgoing international funds transfer instructions through its mobile app and web app. The company transfers all collected remittances on behalf of customers through banking systems, exclusively to Nepal.
A.1.4 Management of AML/CTF Risks:
Instant Exchange acknowledges inherent risks associated with international fund transfers and recognizes the interaction of regulatory, business, and cross-border risks, making risk management complex. The company categorizes risks as regulatory risks, digital currency exchange risks, and remitter risk based on likelihood, consequence, and potential treatments/actions.
A.2 Employee Due Diligence:
Instant Exchange has an employee due diligence program in place. The company's director and compliance officer, responsible for overseeing activities, have obtained Australian Federal Police National Police Certificates and Ministry of Home Police Headquarters Nepal records.
A.3 Risk Types & Risk Indicators:
The company has identified and categorized risk types and risk indicators related to customer profiles, delivery methods, and remitter risks. Controls, including obtaining minimum KYC information, ongoing transaction monitoring, and employee risk awareness training, are employed based on risk ratings.
A.4 Risk Management:
Instant Exchange adopts a risk management strategy involving ongoing customer due diligence, monitoring ML/TF risk profiles, assessing risks' likelihood and impact, and implementing controls relevant to risk levels. The company regularly updates and reassesses risks to mitigate and manage potential risks effectively.
Instant Exchange Pty Ltd will maintain detailed records of customer information, transaction records, and employee due diligence documents as required by AML/CTF regulations.
Instant Exchange Pty Ltd will file reports with relevant regulatory authorities as mandated by local AML/CTF laws and regulations. The company will conduct periodic internal audits to assess the effectiveness of the AML/CTF program and identify areas for improvement.
All employees of Instant Exchange Pty Ltd will undergo regular AML/CTF training to ensure they understand their responsibilities and the importance of detecting and reporting suspicious activities. The company will maintain records of employee training sessions.
Instant Exchange Pty Ltd will implement a sanctions screening system to ensure it does not engage in transactions with individuals or entities on government sanctions lists.
Instant Exchange Pty Ltd will stay informed about changes in AML/CTF regulations and adjust its program accordingly to ensure compliance with evolving requirements.
This AML/CTF policy shall be communicated to all employees, and compliance with this policy will be regularly monitored and enforced. Instant Exchange Pty Ltd is committed to fostering a culture of compliance and vigilance against money laundering and terrorist financing activities.
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Instant Exchange Pty Ltd ACN 644 329 395 is regulated by the Australian Securities and Investments Commission (‘ASIC’), is a registered remittance provider with the Australian Transaction Reports and Analysis Centre (‘AUSTRAC’)
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