Cross-Border Payments & FX Policy¶
| Code | PAY-004 |
| Domain | Payments & Settlement |
| Owner | Head of Treasury |
| Status | Draft |
| Applicability | Platform |
| Jurisdiction | NZ + AU |
| Business domain | BD03 |
| Review date | 2027-03-25 |
Regulations: AML/CTF Act 2006 · AML/CFT Act 2009 · RBNZ FX Guidelines¶
Purpose¶
Govern FX rate setting, spread policy, rate lock mechanics, customer disclosure obligations, IFTI and CMIR regulatory reporting, and correspondent banking risk for cross-border payments. Ensures the platform operates cross-border transfers with transparent pricing, correct reporting, and controlled correspondent exposure.
Scope¶
All cross-border payment instructions in any currency pair processed by the platform, including inbound and outbound international transfers for NZ and AU customers, and NZD↔AUD wallet transfers where the FX spread economics are applied to the customer.
Policy statements¶
Every cross-border payment instruction SHALL display the applicable FX rate, spread, and total cost to the customer before the instruction is authorised. The customer SHALL explicitly acknowledge the disclosed rate before execution proceeds. Silent rate application is prohibited.
FX rates applied to customer transactions SHALL be sourced from the approved rate feed and SHALL NOT deviate from the approved spread policy without explicit approval from the Treasury function. Rate feed failures SHALL cause cross-border payments to queue rather than apply a stale or estimated rate.
Rate lock windows SHALL be defined per currency pair. Where a payment cannot be settled within the rate lock window, the rate SHALL be refreshed and the customer re-informed. Rate expiry SHALL not cause silent re-pricing.
NZD↔AUD wallet transfers SHALL be treated as cross-border FX transactions for disclosure and rate-lock purposes. The wallet product design SHALL clearly communicate whether a competitive rate or a mid-market rate applies, and the spread SHALL be disclosed at the time of transfer initiation.
Where a cross-border payment must be reversed or recalled, the reversal amount SHALL reflect the original transaction economics. The platform SHALL maintain a record of the applied rate and spread for every cross-border instruction to support accurate reversal calculations.
The platform SHALL report all qualifying international funds transfer instructions (IFTI) to AUSTRAC and qualifying cross-border wire transfers to the applicable NZ reporting authority within the statutory timeframe. The reporting module SHALL flag each qualifying payment and confirm submission.
Multi-currency postings SHALL record each currency leg, the applied rate, the spread, and the affected internal or nostro positions so that the complete FX economics of each transaction are auditable.
Correspondent banking arrangements used for cross-border settlement SHALL be risk-assessed before activation and reviewed annually. The platform SHALL maintain a current register of active correspondents and SHALL have a defined process for correspondent deactivation.
Source of funds screening SHALL be applied to inbound international receipts above the applicable threshold. Receipts that cannot be attributed to a known sender or expected purpose SHALL be routed to a controlled exception state.
Satisfying modules¶
| Module | Name | Mode | Description |
|---|---|---|---|
| MOD-004 | Multi-currency ledger (NZD/AUD) | LOG |
Every NZD/AUD conversion recorded as matched pair through FX nostro — full audit trail |
| MOD-025 | FX rate lock & conversion | LOG |
FX rate applied to each conversion is locked and recorded — no post-hoc rate adjustment possible |
| MOD-050 | Disclosure enforcement module | GATE |
FX rate and spread shown and acknowledged before cross-border transfer executed |
Part of Payments & Settlement · Governance overview
Compiled 2026-05-22 from source/entities/policies/PAY-004.yaml