The money remittance industry is extremely diverse, ranging from large international companies with outlets worldwide to small, independent convenience stores in communities with population concentrations that do not necessarily have access to traditional banking services.

The range of products and services offered, and the customer bases served are equally diverse.

The definition of money remitter is wide, but the types of businesses are quite distinct. Some offer a variety of services, whilst others only offer money services as an ancillary component to their primary business.

The Money Laundering and Terrorist Financing (ML/TF) risks associated with the money remittance sector include:

• Due to the number of transactions and intermediaries each transaction does not always have a single coherent set of documentation which identifies the remittance chain
• Remittance businesses have not always been obliged to identify their customers and may receive instructions over the phone or by other non-face to face means, so they may not always know for whom they are acting
• The use of intermediaries and the possible consolidation of remittances into one sum means that money is coming in from many sources and no one person or organisation may have responsibility for knowing the identity of all the sources

Businesses within the money remittance sector captured by the AML/CTF obligations must ensure the organisation conducts a comprehensive ML/TF risk assessment to identify, assess, mitigate and manage ML/TF risk exposures. This is a critical first step in complying with AML/CTF laws.

These are the services offered by money remitters included as designated services under the AML/CTF Act.

• Transferring money or value for, or on behalf of, a customer
• Trading for the accounts of customers in foreign exchange
• Money or currency changing

If you offer or provide one or more of the above products or services, your business will be subject to AML/CTF obligations.

The AML/CTF regime is risk based, which means that your responses to the AML/CTF obligations placed upon you should be risk-based. 

A risk-based AML/CTF regime requires that you understand and address the Money Laundering and Terrorism Financing (ML/TF) risks associated with the remittance services you offer.

You must then design, implement and maintain systems, procedures and controls that are proportionate to your ML/TF risks.

Initialism are the AML/CTF experts, so you don’t have to be.

With over 30 years of expert knowledge and real world experience our AML/CTF compliance solutions will to help you navigate your legal and regulatory requirements so that your business complies with its AML/CTF obligations in the fastest and most cost-effective way.

Initialism has a range of AML/CFT solutions to support your business in becoming AML/CFT compliant and maintaining compliance:

• AML Connect – online with automated support
• AML Complete – expert guided workshop support
• AML Consult – one to one expert support

Our solutions allow you to tailor support based on your capacity, experience and budget.

Initialism can also provide training and advisor AML/CTF solutions that can help your business achieve and maintain AML/CTF compliance.

• AML Coach – AML/CTF Officer Training to understand your obligations
• AML Counsel – advice and support to implement AML/CTF in your business