Our Commitment
Business IT and services Pty Ltd, trading as MoneyFirst ("MoneyFirst", "we", "us", "our"), is committed to the highest standards of compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) laws. We have zero tolerance for money laundering, terrorism financing, fraud or any other financial crime, and we take active steps to prevent our services from being misused for these purposes.
Regulatory Framework
MoneyFirst is registered with and regulated by the Australian Transaction Reports and Analysis Centre (AUSTRAC) as a remittance (money transfer) service provider. We operate in accordance with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), the AML/CTF Rules made under that Act, and all other applicable Australian laws.
Our AML/CTF Program
We maintain a written AML/CTF Program designed to identify, mitigate and manage the risk that our services could be used to facilitate money laundering or terrorism financing. The Program is approved by senior management, reviewed regularly, and overseen by a designated AML/CTF Compliance Officer.
Know Your Customer (KYC)
Before you can send money with MoneyFirst, we are required by law to verify your identity. We may collect and verify information including:
Your full legal name
Your date of birth
Your residential address
- Government-issued photo identification
- The source of your funds and the purpose of your transfer, where required
We may decline to establish a relationship, or to process a transaction, if we are unable to satisfactorily verify your identity.
Ongoing Customer Due Diligence
We monitor our customer relationships on an ongoing basis to ensure transactions are consistent with what we know about each customer, their profile and their risk rating. We may request additional information or documentation at any time, and we apply enhanced due diligence to higher-risk customers and transactions.
Transaction Monitoring
All transactions are subject to automated and manual monitoring to detect unusual or suspicious activity — including transactions that appear inconsistent with a customer's normal behaviour, that appear structured to avoid reporting thresholds, or that are otherwise indicative of financial crime.
Sanctions and PEP Screening
We screen customers and recipients against applicable sanctions lists and politically exposed person (PEP) databases. We will not process transactions involving sanctioned individuals, entities or countries.
Reporting Obligations
In line with our legal obligations, MoneyFirst reports to AUSTRAC, including:
- Suspicious Matter Reports (SMRs), where we form a suspicion on reasonable grounds
- Threshold Transaction Reports (TTRs), for cash transactions of AUD 10,000 or more
- International Funds Transfer Instructions (IFTIs), for transfers into or out of Australia
We are not permitted to "tip off" any person that a report has been, or may be, made to AUSTRAC.
Record Keeping
We retain customer identification and transaction records for at least seven (7) years, as required by law.
Staff Training
Our staff receive regular AML/CTF training appropriate to their role, so they can recognise and respond to the risks of money laundering and terrorism financing.
Prohibited Use
You must not use MoneyFirst for any unlawful purpose, including money laundering, terrorism financing, fraud, or sending money on behalf of another person without disclosing it to us. We may delay, suspend or refuse any transaction, and may close any account, where we have concerns about compliance or financial crime.
Your Responsibilities
By using MoneyFirst you agree to provide accurate and complete information, to cooperate with our identity and verification requests, and to send money only to people you know, for legitimate purposes.
Contact
If you have any questions about this policy, or wish to report a concern, please contact our AML/CTF Compliance team at support@moneyfirst.com.au or by post at 29/97 Creek St, Brisbane City QLD 4000, Australia.