Aspects of the products and services offered by money remitters have been identified as being attractive to criminals wanting to launder the proceeds of crime and to finance terrorism.

Why do money remitters have AML/CTF obligations?

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.

What are the ML/TF risks faced by money remitters?

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 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.

What services are covered by AML/CTF obligations?

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.

What is a risk based AML/CTF regime?

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.

How can Initialism help?

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

With over 50 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/CTF solutions to support your business in becoming AML/CTF compliant and maintaining compliance.

AML/CTF compliance solutions
for money remitters

Our AML/CTF compliance solutions for the money remittance sector draw on unparalleled expertise, knowledge and real-world experience.

Why choose Initialism?


Our expertise covers all AML/CTF disciplines and brings unique perspectives, approaches and solutions to the AML/CTF challenges faced by the money remittance sector


Our AML/CTF compliance knowledge includes working with money remittance businesses and we understand what compliance means for your business


We have experience in delivering workable AML/CTF compliance to the money remittance sector


Our knowledge and expertise has been hard earned and comes from working in the area of AML/CTF for many decades


We have experience in providing tried and tested AML/CTF solutions, regardless of the size and complexity of your money remittance business


Our AML/CTF compliance solutions are flexible and can be tailored to your capacity, experience and budget