Cross-border wallet¶
| Product ID | PRD-004 |
| Launch tier | 1 |
| Jurisdiction | NZ + AU |
| Status | Planned |
| Regulations | AML/CFT Act 2009 · AML/CTF Act 2006 · Privacy Act 2020 · Privacy Act 1988 |
Tier 1 product. Enables customers to hold, move, and spend across NZD and AUD from a single account relationship with full FX transparency.
Option A — Direct bank wallet (launch scope)¶
A customer of the direct bank holds both a NZD account and an AUD account under a single KYC record. They see both balances in a unified dashboard expressed in NZD-equivalent total, and can transfer between currencies through a rate-lock flow.
What the customer sees: - Unified balance dashboard (NZD + AUD equivalent) - Live mid-market rate + explicit spread before any transfer is confirmed - 45-second rate-lock window - Settled to their AU account within 2 minutes (p99)
What the system does: - MOD-025 (FX rate lock) holds the rate and executes an atomic dual-ledger post: debit NZD account, credit AUD account, post the FX gain/loss entry, mark the NZD position closed - MOD-026 (IFTI/CMIR trigger) fires on any qualifying cross-border transfer — NZD 1,000+ (NZ) or AUD 10,000+ equivalent (AU) — and routes the report to the AML reporting pipeline - MOD-004 (multi-currency ledger) maintains separate currency sub-ledgers per account; no commingling - MOD-022 (payment audit trail) records every FX transaction with rate, spread, timestamp, and both ledger entries
Regulatory obligations: - PAY-004: FX spread disclosed before confirmation — satisfied by rate-lock UX - AML-008: IFTI/CMIR automated — MOD-026 GATE mode, no bypass - CON-005: All-in cost shown explicitly; no hidden margins - CON-004: Product disclosure statement issued at account opening
Related ADR: ADR-015
Option B — Inter-institutional wallet (under consideration)¶
An extension of the wallet concept to work across institutions on the same platform. A customer of Institution NZ (a Track 2 SaaS tenant) gains access to an AUD wallet held at a partner Institution AU (another Track 2 tenant), without opening a second full account relationship.
This is a customer-level Vostro construct: Institution AU holds AUD on behalf of Institution NZ's customer, with KYC attested by Institution NZ via platform API rather than re-run by Institution AU.
How it works¶
- Customer completes full KYC at their home institution (Institution NZ) — eIDV, CDD tier, sanctions screen
- Customer opts in to an AUD wallet — the platform calls Institution AU's tenant API with a KYC attestation (CDD tier, verification standard, date, document type — no raw PII transmitted)
- Institution AU accepts the attestation under a documented CDD reliance agreement (FATF Recommendation 17) and opens a wallet sub-account in the customer's name
- Customer can receive AUD, spend via Institution AU's card rails, and transfer back to their NZD account at any time
- FX conversion is settled between the two institutions' liquidity positions before touching the external correspondent channel — tighter spreads than the retail FX market
The KYC reliance framework¶
FATF Recommendation 17 permits an institution to rely on a third party's CDD provided the relying institution can obtain the CDD information immediately, the third party is regulated in a compliant jurisdiction, and a formal reliance agreement is in place. NZ and AU are both FATF member jurisdictions. Both RBNZ (AML/CFT Act 2009, s.32) and AUSTRAC (AML/CTF Act 2006, s.38) have legislative provisions for CDD reliance.
The platform KYC attestation API transmits verification outcome, standard, and date — not raw identity documents or biometrics. The receiving institution retains the right to escalate to EDD for any customer it assesses as higher risk.
What needs to be resolved before Option B proceeds¶
| Item | Dimension | Note |
|---|---|---|
| CDD reliance agreement template | Legal / AML | Required between every tenant pair; platform provides template |
| Cross-border data transfer | Privacy | Customer consent required; NZ Privacy Act 2020 s.212 (cross-border disclosure); AU Privacy Act 1988 APP 8 |
| AU licensing for NZ institution | Regulatory | Whether NZ institution holding AUD for NZ customers requires AFSL or AUSTRAC remittance registration — depends on account structure |
| Attestation API specification | Architecture | New platform-level module; no ADR yet |
| Inter-institutional FX settlement | Operations | Bilateral liquidity agreement required between tenant institutions |
| Wallet classification | Regulatory | Whether the AUD wallet constitutes a stored value facility under AU regulations |
No ADR has been raised for Option B. The above items need legal and compliance sign-off before design begins.
Why this matters commercially¶
Every institution that joins the platform increases the value of every other institution's customers. A customer of SBS Bank in Invercargill gains access to an AUD wallet at a COBA member in Melbourne — using infrastructure both institutions already run. The network effect is the moat: FIS, Fiserv, and Mambu have no equivalent interconnection layer because their deployments are isolated silos.
At sufficient volume, the inter-institutional FX pool enables spread compression well below the correspondent channel rate — a material improvement over what any individual institution can offer today.
Related¶
- ADR-015 — cross-border wallet design (Option A)
- AML-008 — IFTI/CMIR reporting policy
- AML-009 — correspondent banking policy (relevant to Option B CDD reliance)
- PAY-004 — cross-border FX policy
- market-opportunity.md — SaaS strategy and inter-institutional network context
- MOD-025 — FX rate lock module
- MOD-026 — IFTI/CMIR trigger module
Key terms¶
| Term | Value |
|---|---|
| Currencies held | NZD and AUD (Option A launch scope) |
| FX conversion | Live mid-market rate plus spread; 45-second rate lock |
| Rate lock window | 45 seconds from confirmation screen |
| FX fee | Per fee schedule (spread disclosed as separate line item, not embedded in rate) |
| Minimum transfer | Per fee schedule |
| Settlement | Converted funds available in destination currency account in real time after rate-lock acceptance |
| IFTI/CMIR threshold | NZD 1,000 (NZ); AUD 10,000 (AU) — automatic regulatory reporting |
| Statement frequency | Monthly, covering all currency sub-accounts |
System capabilities¶
- Exchange rate locked for 45 seconds — customer sees the exact amount they will receive before confirming.
- FX spread disclosed as a separate explicit line item — not hidden in the exchange rate.
- Settlement in real time after lock acceptance — no 1–2 business day delay.
- IFTI/CMIR reporting fully automated (MOD-026) — customer has no filing obligation.
- NZD-equivalent total shown in real time on the dashboard, updated with mid-market rates.
Governing policies¶
- PAY-004 — Cross-Border Payments & FX Policy
- AML-008 — Cross-Border Transfer Reporting Policy
- CON-004 — Product Disclosure & Sales Practice Policy
- CON-005 — Fee & Pricing Transparency Policy
- PRI-001 — Privacy Policy
Implementation modules¶
| Module | Name | Status |
|---|---|---|
| MOD-004 | Multi-currency ledger (NZD/AUD) | Deployed |
| MOD-020 | Pre-payment validation suite | Deployed |
| MOD-022 | Payment audit trail | Deployed |
| MOD-025 | FX rate lock & conversion | Deployed |
| MOD-026 | IFTI / CMIR reporting trigger | Deployed |
| MOD-105 | Product eligibility engine | Not started |
| MOD-110 | Fee engine | Deployed |
| MOD-113 | Statement generation | Not started |
Compiled 2026-05-22 from source/entities/products/PRD-004.yaml