Cross-Border Transfer Reporting Policy¶


Code	`AML-008`
Domain	AML / Financial Crime
Owner	Chief Compliance Officer
Status	Draft
Applicability	Platform
Jurisdiction	NZ + AU
Business domain	BD07
Review date	2027-03-25

Regulations: AML/CTF Act 2006 · AML/CFT Act 2009 ¶

Purpose¶

Govern the obligations for cross-border payments, including travel rule compliance, originator and beneficiary information requirements, and correspondent banking risk management.

Scope¶

All cross-border payment transactions sent or received by the platform, and all correspondent banking relationships.

Policy statements¶

The platform SHALL comply with the FATF Travel Rule for all cross-border electronic funds transfers. Originator information (name, account number, address or national identity number or date and place of birth) and beneficiary information (name, account number) SHALL be transmitted with every covered transfer.

Cross-border transfers without required originator or beneficiary information SHALL be rejected or returned. The platform SHALL NOT process incomplete transfers unless the missing information can be obtained through the straight-through process.

The platform SHALL apply enhanced scrutiny to transfers to or from high-risk jurisdictions as defined by the FATF list and the platform's own jurisdiction risk assessment.

Correspondent banking relationships SHALL be subject to EDD before establishment, including: assessment of the respondent's AML/CFT controls, regulatory status, and ownership structure. Shell bank relationships SHALL be prohibited.

Correspondent banking relationships SHALL be reviewed at least annually. Any relationship where the respondent's AML/CFT controls are assessed as inadequate SHALL be terminated or placed on heightened monitoring.

IFTI reports for cross-border transfers SHALL be filed in accordance with AML-006.

Satisfying modules¶

Module	Name	Mode	Description
MOD-004	Multi-currency ledger (NZD/AUD)	`AUTO`	Cross-border transfer flag applied automatically on NZD↔AUD conversions for CMIR/IFTI reporting
MOD-016	Rule-based typology engine	`AUTO`	Cross-border transfers flagged automatically for IFTI/CMIR threshold check
MOD-019	Regulatory report submission module	`AUTO`	IFTI and CMIR reports submitted automatically — no manual data extraction or formatting
MOD-026	IFTI / CMIR reporting trigger	`AUTO`	No reportable transfer can be missed — threshold check applied to every cross-border event
MOD-067	Trade finance operations	`LOG`	Logs all cross-border trade finance transactions and counterparty details for AML screening and reporting.
MOD-154	Correspondent banking risk gate	`LOG`	All correspondent-routed cross-border payments are flagged for IFTI/CMIR evaluation in the cross-border reporting pipeline.

Part of AML / Financial Crime · Governance overview Compiled 2026-05-22 from source/entities/policies/AML-008.yaml