Multi-Currency Deposit / Wallet¶
| Product ID | PRD-007 |
| Launch tier | 2 |
| Jurisdiction | NZ + AU |
| Status | Planned |
| Regulations | AML/CFT Act 2009 · AML/CTF Act 2006 · Privacy Act 2020 · Privacy Act 1988 |
The multi-currency wallet allows customers to hold, convert, and transact in multiple currencies alongside their base NZD or AUD account. Each currency is maintained as a separate sub-ledger with no commingling. Exchange rates are locked for up to 24 hours before execution, eliminating rate uncertainty on large or time-sensitive transfers.
Key terms¶
| Term | Value |
|---|---|
| Account type | Multi-currency deposit wallet |
| Base currency | NZD (NZ) / AUD (AU) |
| Additional currencies | USD, EUR, GBP, SGD, JPY (per institution configuration) |
| FX conversion | Mid-market rate plus spread; disclosed before confirmation; rate lock up to 24 hours |
| FX fee | Per fee schedule (spread shown as explicit line item) |
| FX revaluation | Daily — NZD/AUD-equivalent total updated with mid-market rates |
| Minimum conversion amount | Per fee schedule |
| Sub-ledger isolation | Each currency held separately; no commingling across currencies |
| Statement frequency | Monthly, covering all currency sub-accounts |
System capabilities¶
- Rate locked for up to 24 hours — customer can commit to a conversion without executing it immediately.
- FX spread always disclosed as a separate explicit item — never embedded in the exchange rate.
- Running NZD/AUD-equivalent total updated daily with mid-market rates.
- Daily FX revaluation entries posted automatically (MOD-004) — no manual reconciliation.
- Each currency sub-ledger independently balanced and auditable.
- IFTI/CMIR reporting automated on qualifying cross-border transfers — no customer filing obligation.
Eligibility¶
Assessed automatically by MOD-105. Requires verified KYC (MOD-009), CDD tier assigned (MOD-010), no active sanctions match (MOD-013), and jurisdiction match. Customers must hold or open a base NZD or AUD account as the funding source.
Account opening¶
Customer selects the currencies to activate through the app. MOD-049 captures consent for each currency wallet. MOD-050 delivers the applicable product disclosure. MOD-007 transitions each sub-account to ACTIVE. No additional identity verification is required if the customer already holds a verified account. The full activation process completes in-session.
Fees¶
| Fee type | Amount |
|---|---|
| FX conversion fee (spread) | Per fee schedule — disclosed as explicit line item before confirmation |
| Monthly wallet fee | Per fee schedule |
| Paper statement fee | Per fee schedule |
Interest¶
Sub-accounts in non-base currencies are non-interest-bearing. Interest on the base NZD or AUD balance (if applicable) is governed by the terms of the underlying deposit account.
Statements¶
Generated monthly by MOD-113 covering all active currency sub-accounts. Each statement shows opening balance per currency, all transactions, FX conversion entries, daily revaluation entries, and closing balance per currency with NZD/AUD equivalent. Delivered to the in-app document vault; available as PDF download. Retained for 7 years.
Closing / exit terms¶
Each currency sub-account must be reduced to a zero balance before closure — by converting to the base currency or transferring out. Unconverted balances cannot be left in a closing wallet. Conversions at closure apply the prevailing mid-market rate plus the standard spread per fee schedule. On all sub-accounts reaching zero, MOD-007 transitions the wallet to CLOSED.
Regulatory¶
New Zealand: AML/CFT Act 2009 — IFTI reporting for qualifying transfers per AML-008; Privacy Act 2020; Financial Markets Conduct Act 2013 — FX disclosure per PAY-004.
Australia: AML/CTF Act 2006 — CMIR reporting for qualifying transfers per AML-008; Privacy Act 1988; cross-border FX disclosure obligations per PAY-004.
Governing policies¶
- PAY-004 — Cross-Border Payments & FX Policy
- CON-001 — Customer Fairness & Conduct Policy
- CON-004 — Product Disclosure & Sales Practice Policy
- CON-005 — Fee & Pricing Transparency Policy
- CON-006 — Product suitability and governance
- AML-003 — Know Your Customer (KYC) & Identity Verification Policy
- AML-008 — Cross-Border Transfer Reporting Policy
- PRI-001 — Privacy Policy
Implementation modules¶
| Module | Name | Status |
|---|---|---|
| MOD-001 | Double-entry posting engine | Deployed |
| MOD-002 | Immutable transaction log | Deployed |
| MOD-003 | Real-time balance engine | Deployed |
| MOD-004 | Multi-currency ledger (NZD/AUD) | Deployed |
| MOD-007 | Account state machine | Deployed |
| MOD-020 | Pre-payment validation suite | Deployed |
| MOD-025 | FX rate lock & conversion | Deployed |
| MOD-044 | JWT role-based access control | Deployed |
| MOD-049 | Open banking consent management | Deployed |
| MOD-068 | Authentication & session management | 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-007.yaml