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The amendments to the AML/CTF Act introduce a shift from International Funds Transfer Instruction (IFTI) reporting to International Value Transfer Service (IVTS) reporting. This change broadens the scope of reporting to include not only traditional funds transfers but also transfers involving virtual assets and other forms of value.
The new IVTS reporting regime captures a wider range of transactions, ensuring comprehensive coverage of value transfers across different types of reporting entity, including financial institutions, remittance service providers, gambling businesses and virtual asset service providers.
Reporting entities undertaking transfers of value covered by the IVTS regime should address the challenges represented by IVTS reporting proactively to ensure they are able to navigate the complexities of the new IVTS reporting obligations and ensure compliance with the revised AML/CTF Act.
The International Funds Transfer Instruction (IFTI) reporting regime is a critical component of AML/CTF framework. It requires certain businesses to report international funds transfers to AUSTRAC.
The International Value Transfer Service (IVTS) reporting regime is being introduced as part of the AML/CTF Amendment Act 2024 to replace the IFTI regime. It aims to enhance the transparency and security of international value transfers, including those involving virtual assets.
Currently businesses are required to submit IFTI reports to AUSTRAC within 10 business days of the transfer instruction being sent or received. The reports must include detailed information about the payer, the payee, and the transaction itself.
The following types of businesses are required to report IFTIs:
Financial institutions that facilitate international electronic funds transfers.
Remittance service providers that offer international money transfer services, including those that operate through agents or sub-agents known as affiliates.
Casinos that handle international transfers of money or property as part of their operations.
IFTI reporting requirements apply based on specific elements of a transaction. These elements include:
Originating country: The country where the instruction to transfer funds originates is overseas.
Destination country: The country where the funds are to be made available is overseas.
Transfer method: Whether the transfer is electronic or involves other methods such as remittance arrangements.
There are currently two main types of IFTI reports:
IFTI-E (Electronic): Applies to electronic funds transfers sent or received from another country by financial institutions.
IFTI-DRA (Designated Remittance Arrangement): Applies to transfers of money or property by businesses that are not financial institutions, such as remittance service providers and casinos.
Like IFTI’s, businesses will be required to submit IVTS reports to AUSTRAC within 10 business days of the transfer instruction being sent or received. The reports will need to include detailed information about the payer, the payee, and the transaction itself. The value being transferred can include money, virtual assets, or property.
The following types of businesses will be required to report under the new IVTS regime:
Financial institutions that facilitate international value transfers.
Remittance service providers that facilitate international value transfers, including those that operate through agents.
Gambling businesses that handle international value transfers as part of their operations.
Virtual Asset Service Providers (VASPs) involved in the exchange, transfer, safekeeping, or administration of virtual assets that handle international value transfers.
VTS reporting requirements apply based on specific elements of a transaction. These elements include:
Accepting an instruction for the transfer of value internationally on behalf of a payer in Australia.
Making the transferred value from an international transfer available to the payee in Australia.
Type of Value Transferred the value being transferred can include money, virtual assets, or property.
The introduction of the International Value Transfer Service (IVTS) reporting obligations under the revised AML/CTF Act presents several challenges for reporting entities:
Complexity of transactions: IVTS transactions can involve multiple parties and jurisdictions, making it difficult to trace and report accurately. This can only be systematically addressed through the implementation of advanced transaction monitoring systems that can track and analyse complex transaction chains, which will need to be regularly updated to adapt to new transaction patterns.
Data management and integration: Reporting entities may struggle with integrating data from various sources and ensuring data quality and consistency. This will require them to invest in robust data management solutions that facilitate seamless integration and ensure data accuracy. They will also need to conduct regular data audits to ensure high data quality standards are maintained.
Resource allocation: Complying with the new IVTS reporting obligations may require significant resources, including time, money, and personnel. In order to understand the impact on current business processes and resources a thorough risk assessment to prioritise resource allocation based on the entity's specific risk profile. Some reporting entities might need to consider outsourcing functionality to specialised service providers if internal resources are limited, which could increase compliance complexity and cost.
Technological adaptation: Adapting existing systems to meet new reporting requirements can be technically challenging and costly. A phased implementation plan will be required to upgrade systems gradually and will necessitate collaboration with technology vendors to ensure solutions are tailored to fully meet the IVTS reporting requirements.
Cross-Border coordination: Coordinating compliance efforts across different jurisdictions with varying regulations to ensure you receive full information can be complex. The establishment of clear communication channels and protocols for cross-border compliance will be important which may include working with international partners to harmonize compliance efforts and share best practices.
By addressing these challenges proactively, reporting entities can better navigate the complexities of the new IVTS reporting obligations and ensure compliance with the revised AML/CTF Act.
We are here to help
Although the new AML/CTF requirements won't be enforced until 2026, it is vital to start planning and preparing for compliance with the revised AML/CTF requirements now.
With a short lead time to compliance and limited AML/CTF experts across Australia, demand will only continue to increase as the compliance date approaches.
If you would like to discuss any of the above with one of our AML/CTF specialists, please reach out.
Learn more about how our Anti-Money Laundering reforms services can help you
The current AML/CTF regime only extends to digital currency exchanges regulating exchanges between digital currency and fiat currency. The new Act introduces significant amendments to extend coverage to a broader range of virtual assets and virtual asset service providers (VASPs) through a revised set designated service.
The revised Australian AML/CTF Act 2024 introduces the concept of value transfer chains to enhance transparency and traceability in value transfers, including money, virtual assets, and property.
Australia's AML reforms are transitioning the initial Customer Due Diligence (CDD) requirements from the AML/CTF Rules to the AML/CTF Act, focusing on an outcomes-based framework to enhance clarity and effectiveness of CDD processes.
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