The layman's guide to AML/CTF Rules 2025: Part 4 - Registration

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Understanding Registration under Australia’s AML/CTF Rules 2025

Part 4 explains how Remittance providers and Virtual Asset Service Providers (VASPs) can to get on, stay on and be shown on AUSTRAC’s Remittance and VASP registers. It explains the steps for applying, being assessed, keeping details up to date and what happens if things go wrong. Here’s the quick version:

• Registers and publication: AUSTRAC maintains both the Remittance Sector Register and the VASP Register, and publishes key details and any conditions.
• Applying to register: Provide your legal and trading names, ABN or ACN, structure, services, owners and controllers, contact details, countries you deal with, bank accounts, ML/TF risk assessment, AML/CTF policies and training, third-party help and key people checks.
• Role-specific extras: RNPs, independent dealers, affiliates and VASPs have extra fields. Include affiliate consent or suitability checks, any super-agent arrangements, delivery channels, expected volumes and values, and (for VASPs) wallet details and supported assets.
• How AUSTRAC decides: AUSTRAC looks at criminal and regulatory history, accuracy of information, whether the business is real and resourced, and your capability to comply.
• Suspension: Registration can be suspended for specified risks or breaches for up to 3 months, with one extension. It’s noted on the Register, can be revoked if issues are fixed, and you must still notify changes and can still renew.
• Cancellation and publication: Similar factors apply to cancellation. AUSTRAC may publish your name and the cancellation date.
• Renewal: Apply in the 90 days before expiry. If you apply on time your registration continues until AUSTRAC decides. Renewals last 3 years.
• Ongoing notifications: Tell AUSTRAC promptly about material changes and keep registrable details current. Network providers must also keep affiliate details accurate.
• Spent convictions: Standard spent-conviction protections apply to disclosures and decisions.

In essence, Part 4 is about entry and ongoing suitability: clear applications, honest disclosure, timely updates, and AUSTRAC oversight to protect the system.

Useful links

• The Act
• The AML/CTF Rules 2025
• Explanatory Statement

Designated services 

• Tranche 1 - table 1
• Tranche 2 - Schedules 3 and 6

Division 1 - Management of the Remittance Sector Register and the Virtual Asset Service Provider Register

4-1: Correction of entries

If AUSTRAC spots a mistake or missing information on either Register, the AUSTRAC CEO can fix it and must let the affected business know. If the entry is for a remittance affiliate, the network provider is notified too.

4-2 Publication of register information

AUSTRAC must publish key registration details on its Remittance register including:

• The person or business name
• Their registration type: remittance network provider, independent remittance dealer, or remittance affiliate
• If an affiliate, the name of their network provider
• Any conditions attached to their registration
• The date their registration starts
• Their key registrable details (the business info AUSTRAC requires on file)

AUSTRAC must also publish the name of the person and the registrable details in relation to the person on the VASP register. If they deem necessary they can also publish any conditions attached to the person's registration

Division 2 — Information requirements for registration applications

4-3: Purpose of this Division

This Division lists the information you must include when applying to be a remittance network provider, independent remittance dealer, remittance affiliate, or a virtual asset service provider.

4-4 Application - general information

Applications must include full legal and trading names, identifiers (ABN/ACN etc), any foreign licences, business addresses, legal form, beneficial owners’ details, contact details, website domains, what the business does, permanent establishments, expected turnover and countries you’ll deal with.

It must also include who completed the form, their details and a truth declaration.

If you’re a company, partnership, trust, association or co-operative then other details are required:

• Body corporate: directors’ names/aliases/former names, DOB/place, director IDs; country of incorporation and any other registrations; overseas principal business address (if applicable).
• Partnership: partnership terms; identity details for each partner. If a partner is a company, use body-corporate info; if an association, use association info; if a trustee, provide the trust name and trust info.
• Trust: trust type and former names; identity details for each trustee, beneficiary, settlor, appointer, guardian and protector (individual or company as applicable).
• Association or co-operative: identity details for the person(s) with primary governance and executive responsibility.

Identity details (individual) include: full name, aliases/former names, DOB/place, current and most recent prior residential address, unique identifier.

4-5 Information relating to ML/TF risks

The application must describe the key ML/TF/PF risks you may face - covering customers, countries, products/services, delivery channels and transaction types - and how you review and update your risk assessment.

4-6 Information relating to AML/CTF policies

The application must explain your AML/CTF policies for managing and mitigating risks, complying with the AML legislation, vetting and training staff, keeping policies up to date and carrying out CDD (including how you handle PEPs and any use of distributed-ledger tech - e.g. wallet-ownership checks, blockchain analytics, verifiable credentials

You must also include the name and address of any external training provider used in the 12 months prior to the application. 

4-7 Information relating to accounts with financial institutions

The application must list the accounts you’ll use: who holds/signs them (with full name and DOB), which country the account is in, and what foreign currencies it can hold.

4-8 Information relating to other persons assisting

The application must say whether anyone else will perform or help with tasks tied to your AML/CTF obligations, whether any of that happens overseas (and where), and what quality controls you’ll use for that third party.

4-9 Information relating to key personnel and past unlawful activity etc.

The application must provide name, DOB, job title and contact details for each of the applicant's key personnel, disclose any relevant criminal charges/convictions (ML/TF/PF people smuggling, fraud or a serious offence of any kind), court findings, civil/regulatory actions, steps you took to check your key personnel, and any details of those issues.

Also disclose prior or current applications/registrations or financial-sector licences involving key people, plus their recent training and training provider details.

4-10 Additional requirements for application by remittance network provider for registration of an affiliate

If a network provider applies to register an affiliate, the application must say whether the provider assessed the affiliate’s suitability against the ML/TF/PF risks they would pose (and outcome) and confirm if and when the affiliate consented to the application.

4-11 Additional requirements for application by independent remittance dealer for registration as a remittance affiliate

If an independent dealer applies to be an affiliate of a specific network, include whether the network provider consented and when.

4-12 Additional requirements for application for registration as an independent remittance dealer or a remittance affiliate of network provider

Say whether you’ll use offsetting or third-party remittance arrangements, your delivery channels and how customers will fund or receive transfers. Include expected monthly volumes and values for relevant designated services in the first 12 months, and disclose any key person’s prior ownership/management roles in similar providers (with details of name, role and period of time they were involved).

4-13 Additional requirements for application for registration as a remittance affiliate of network provider

State if a super-agent (see below) will represent you with the network provider, and whether one of your senior managers will approve the provider’s risk assessment and AML/CTF policies (as the Act allows).

A super-agent is someone who provides admin support to help run the network and represents affiliates in dealings with the provider. (AUSTRAC guidance explains typical super-agent roles and when they are or aren’t captured by the regime.)

4-14 Additional requirements for application for registration as a virtual asset service provider

If applying as a VASP, describe the virtual assets involved, delivery channels, how customers’ money/assets will be used in exchanges, any transaction/time limits, expected monthly volumes/values across relevant designated services for the first 12 months, and each wallet’s supported assets and address.

Division 3 - Registration decisions

4-15: Registration decisions—other matters

When deciding whether to register you, AUSTRAC considers things like criminal history, compliance history of you/your owners/related bodies (and the network provider if relevant), your consent (for affiliate registrations), experience of you and your key people in relation to the nature, size, complexity and ML/TF risks of your business, likelihood you will actually run the business, operational readiness and resourcing. 

Division 4 — Suspension of registration

4-16: Purpose of this Division

This Division sets out how suspension works in relation to persons.

4-17 Suspension of registration

AUSTRAC may suspend your registration if you or your key people are charged/convicted of AML-related offences (ML/TF/PF, people smuggling, fraud and any other serious offences), found by a court to have breached the regime, face adverse regulatory findings, are currently contravening the law, pose significant ML/TF/serious-crime risk, breach a registration condition, lack capability or appropriate experience, or provided false/misleading info.

4-18 Effect of suspension—renewal and advising of certain matters

Even while suspended, you’re treated as “registered” for two limited purposes: renewal (Division 6) and your duty to tell AUSTRAC about material changes.

(Those duties are set out in the Act: s 75M for remitters and s 76P for VASPs.)

4-19 Period of suspension

Suspension can last up to 3 months. AUSTRAC can extend it once by up to another 3 months if it still reasonably suspects a suspension ground.

4-20 Notice of suspension decision

If suspended, AUSTRAC must promptly give written notice to you (and, where relevant, your affiliates or network provider). The notice explains the suspension effect, start and end dates, and that the suspension can be extended.

4-21 Notice of extension of suspension

If AUSTRAC extends the suspension, it must promptly notify the same parties and state the effect and new end date.

4-22 Revocation of suspension of registration

AUSTRAC can lift the suspension if, based on new information from you, it’s appropriate to do so.

4-23 Notice of decision to revoke suspension of registration

If a suspension is revoked, AUSTRAC must promptly notify the relevant parties and specify the date it ceased.

4-24 Register entry in relation to suspension of registration

AUSTRAC must mark the Register to show a registration is suspended (or remains suspended), and remove that note when the suspension ends or is revoked.

Division 5 - Cancellation of registration

4-25: Cancellation of registration - other matters

For cancellation decisions, AUSTRAC looks at similar factors to suspension: serious offences, court findings, adverse regulatory outcomes, whether you’re actually carrying on the business, operational capability, relevant experience and whether information provided was false/misleading.

4-26 Publication of cancellation information

If your registration is cancelled, AUSTRAC may publish your name and the cancellation date on its website and/or on the relevant Register.

Division 6 — Renewal of registration

4-27 Purpose of this Division

This Division explains how renewal works under the Act.

4-28 Application for renewal of registration

Registered remittance network providers, independent dealers, self-applied affiliates and VASPs may all apply to renew their registration.

A network provider can also apply to renew an affiliate it originally registered.

When applying for renewal you must use the approved form and include the required information (which may include whether you’ve complied with your “material change” notification duties).

4-29 Period within which renewal applications may be made

Apply within the 90 days before your registration would otherwise end.

Note: registrations last 3 years, and if you apply in time your registration can keep running until AUSTRAC decides.

4-30 Determining renewal application

AUSTRAC renews if appropriate, considering: ML/TF and serious crime risk; whether you’ve met your notification duties and kept enrolment/registrable details current; any suspicion the application contains false or misleading information; whether you’re actually operating; and your ongoing operational capability.

4-31 Period for which renewed registrations have effect

A renewed registration lasts 3 years.

4-32 Decision on renewal application is a reviewable decision

If AUSTRAC refuses renewal under 4-30, that decision can be reviewed under the Act.

4-33 Continuation of registration pending decision on renewal application

If you apply on time but AUSTRAC hasn’t decided before the 3-year period ends, your registration keeps going until the decision takes effect.

Division 7 — Matters registered persons required to advise

4-34 Matters registered persons required to advise

You must tell AUSTRAC (or your network provider, in some cases) about:

• any change to your registrable details
• certain changes connected to criminal/civil matters about you or key people
• changes to third-party assistance arrangements
• changes to any foreign registrations/licences
• if you stop providing registrable services
• changes to details of beneficial owners
• changes to which foreign countries you deal with
• for network providers: removing an affiliate from your network

You must also correct the record if you later discover information you or your provider previously gave AUSTRAC was incomplete or inaccurate.

(These obligations sit alongside the Act’s requirement to advise material changes within 14 days.)

Division 8 — Other matters

4-35: Spent convictions

The usual “spent conviction” protections apply: in certain cases people don’t need to disclose spent convictions, and decision-makers must disregard them.