The layman's guide to AML/CTF Rules 2025: Part 8 - Transfers of value

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Understanding Transfers of value under Australia’s AML/CTF Rules 2025

Part 8 explains who counts as the ordering, intermediary and beneficiary institutions in a value transfer, what information must be collected, verified and passed on, and what each party must monitor. It also lists limited exemptions, the updated FATF verification information you can use, and how to decide where value is “in” a country for international transfers.

Here’s the quick version:

• Who’s who: Ordering = you accept the payer’s instruction. Beneficiary = you make value available to the payee. Intermediary = you relay the transfer message.
• Ordering duties: Collect payer information and payee name, verify payer information, pass on payer information, payee name and tracing data. Channel tweaks apply for BECS/BPAY/DEFT, single message files, merchant payments/refunds, ATMs and self-hosted wallets.
• Beneficiary duties: Monitor that required data arrived (general case: payer info, payee name and tracing). Channel rules mirror the above.
• Intermediary duties: Monitor what you received and pass it on unchanged, with a specific rule for the BECS leg of incoming overseas payments.
• Updated FATF payer/payee information : You may use the revised FATF payer/payee information. Tracing data still must travel.
• Exemptions: Certain foreign-branch services kept within the European Economic Area or a single foreign country, inter-Financial Institution transfers, cheque instructions, merchant payments/refunds, limited relief for pre-commencement and certain existing customers, and specific carve-outs for self-hosted wallets.
• International tests: Location rules determine when value is “in” a country and whether a transfer is inbound or outbound.

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 - Ordering institutions and beneficiary institutions

8-1: Determination of who is an ordering institution

You’re an ordering institution if, in the course of business, you accept a payer’s instruction to move value (money, virtual assets or other property).

Practical ways this can happen include where you:

• receive the value from the payer;
• already hold it for the payer (e.g., a bank account or hosted wallet);
• are authorised to draw it from another source (e.g., via a direct-debit mandate or linked account); or
• use an offsetting arrangement with the beneficiary institution. (This aligns with the “value transfer chain” definitions introduced in the Act for Part 5 of the Act — Transfers of value (previously “Electronic funds transfer instructions”).)

8-2 Determination of who is a beneficiary institution

You’re a beneficiary institution if, in the course of business, you make the transferred value available to the payee.

These requirements come from s 64 of Part 5 (collect under s 64(2)(a), verify under s 64(2)(b) by applying ss 28 & 30, and pass-on under s 64(3)), with definitions in ss 70–72

For example by:

• crediting the payee’s account (including a hosted virtual-asset wallet);
• making it available via the payee’s agent;
• placing it with a deposit-taker/credit provider for the payee under an arrangement with the payee; or
• using an offsetting arrangement with the ordering institution.

Division 2 - Transfers of value

8-3 Obligations of ordering institutions - collecting, verifying and passing on information

What you must collect, verify and pass on depends on the channel. 

These requirements come from Part 5 of the Act (Electronic funds transfer instructions), notably section 64 for what to collect, verify and pass on and sections 28 and 30 for how to verify identity which relate to part 6 of the Rules - Customer Due Diligence

General case

Collect: payer information + payee’s full name
Verify: payer information 
Pass on: payer information + payee’s full name + tracing information

Domestic via BECS/BPAY/DEFT

Collect: payer information + payee’s full name
Verify: payer information
Pass on: tracing information

Single message (one message covers multiple transfers; not BECS/BPAY/DEFT):

Collect: payer information + payee’s full name
Verify: payer information
Pass on (for each transfer): payer information + payee’s full name + tracing information

Merchant payment (or refund)

Collect/Verify: not applicable (special rule, because the card issuer already verified the payer, only the card number needs to travel.)
Pass on: the card number used (or original card for refunds)

ATM instruction

Collect & verify: payer’s full name
Pass on: card number used for the withdrawal

Transfer to a self-hosted virtual-asset wallet

Collect: payer information + payee’s full name
Verify: payer information
Pass on: not applicable (special rule, because if the payee controls the wallet themselves (not a bank/VASP), there’s no regulated entity to pass it to)

8-4 Obligations of beneficiary institutions - monitoring for receipt of information

Take reasonable steps to monitor that the required information arrived, based on the channel:

• General: payer information + payee full name + tracing information
• BECS / BPAY / DEFT (domestic): tracing information
• Single message (not BECS/BPAY/DEFT): for each transfer, payer information + payee full name + tracing information
• Merchant / refund / ATM: the card number
• Incoming BECS leg of money from overseas: tracing information
• From a self-hosted wallet: payer information + payee full name + tracing information

8-5 Obligations of intermediary institutions - monitoring for receipt of information and passing on information

As an intermediary, you must:

• take reasonable steps to monitor that you received the required information and pass on what you received, using the same channel-by-channel breakdown as beneficiary institutions as outlined above in 8-4.
• For the incoming BECS leg of an overseas payment, you monitor for payer info + payee full name + tracing, and pass on the tracing info.

8-6 Payment transparency - transition to revised FATF Recommendations

If you choose to use the revised FATF recommendations to collect/verify/pass on (below), you must send both the expanded payer information and the richer payee information.

But the required tracing information is the same no matter if you use FATFs recommendations or those stated in the previous Rules.

Specifically (as from the Act's definitions):

Payer information

• Payer’s name + full address + the ordering institution’s customer ID for the payer and

• One of the following as relevant:

  • (If a body corporate) A government ID number (e.g., ABN/ACN or foreign equivalent), or

  • (If an individual) date of birth plus country and town/city of birt

Account/reference details :

• If the money is sent from a single account the payer holds in Australia with the ordering institution include that account number
• Otherwise, either a unique transfer reference or, if it’s from a single account with the ordering institution, include that account number

Payee full name 

• the payee’s full name and
• the town or locality in which the payee ordinarily resides; and the country in which the payee ordinarily resides - if they are an individual; or
• the town or locality of the payee’s place of business or operations; and the country of the payee’s place of business or operations; and a unique identifier for the payee (if any) - if they are a body corporate

and tracing information 

• the account number; or
• in any case - a unique reference number for the transfer instruction.

Division 3 - Exemptions from obligations relating to transfers of value

8-7 Exemptions- designated services provided at or through foreign permanent establishments

Part 5 (Electronic funds transfer instructions) of the Act doesn’t apply only if all of these are true:

1. You're providing one of the following transfer-of-value services (s 6, table 1):
   1. Item 29: Ordering institution accepts the payer’s instruction
   2. Item 30: Beneficiary institution makes value available to the payee
   3. Item 31: Intermediary institution passes on the transfer message
2. And it is provided at/through your overseas branch (a foreign permanent establishment) under local AML laws that implement FATF standards.
3. And the money/property (not virtual-asset transfers) stays within the European Economic Area (EEA) i.e. (EEA member 1 >> EEA member 2) or stays within the same foreign country.

8-8 Exemptions - transfers of value occurring in specified circumstances

This section lists when Part 5 of the Act - Electronic funds transfer instructions doesn’t apply (made under s 67(1)(b)of the Act).

Inter-financial institution transfers

• Part 5 doesn’t apply if both the payer and the payee are financial institutions and are acting on their own behalf(not for a customer).
• Part 5 also doesn’t apply where the transfer message is sent via SWIFT’s payment delivery system and both parties are SWIFT “Supervised Financial Institutions”, acting on their own behalf.

Cheques

• Part 5 doesn’t apply if the instruction is given by a cheque that is drawn on the ordering institution.

Merchant payments—ordering institution obligations

• For a merchant card payment or a refund, the ordering institution does not need to collect or verify payer information under s 64(2)(a)–(b), and s 64(5)(a) also doesn’t apply.

Pre-commencement customers—ordering institution obligations

• If you act as the ordering institution (item 29 in s 6 table) for a pre-commencement customer, you may skip the s 64(2)(b) verify step if you have no reasonable grounds to doubt the adequacy or truth of the payer information.

Certain existing customers—ordering institution obligations

• If you act as the ordering institution (item 29) and start providing the service before 1 July 2030, you may skip the s 64(2)(b) verify step for a customer covered by ss 6-42 or 6-43, if you have no reasonable grounds to doubt the adequacy or truth of the payer information.

Transfers to a self-hosted virtual asset wallet

• If the destination is a self-hosted wallet, the ordering-institution pass-on duty (s 64(3)) and the beneficiary “monitor receipt” duty (s 64(5)(b)) do not apply. (If the payee controls the wallet themselves—i.e., not a bank/VASP—there’s no one to pass the travel-rule data to.)

Division 4 - International value transfer services

8-9 When value is in a country

For international value transfer services (IVTS), value is treated as “in” a country when, for example:

• it’s provided/held/moved at or through your permanent establishment there;
• an offsetting arrangement is initiated there;
• or the beneficiary institution makes it available there (including deposits to an account or hosted wallet).

These location tests determine whether a transfer is outbound (Australia >> overseas) or inbound (overseas >> Australia) for compliance purposes.