Quick Overview of Affiliate of a Remittance Network Provider
- What it is: A registered remittance provider that operates under a remittance network provider’s brand, products, platforms or systems.
- Why it matters: It shapes who must register, how customer due diligence is carried out, and how oversight works across a network.
- Most relevant to: Remittance businesses, agent or franchise remitters, and group models that deliver remittance services through a central network.
What is Affiliate of a Remittance Network Provider?
AUSTRAC defines an affiliate of a remittance network provider as a registered remittance service provider that has an agreement with a remittance network provider to use the network’s brand, products, platforms or systems to provide the remittance service. Under that agreement, the affiliate accepts instructions from customers to send funds to a recipient in another location.
In plain English, the affiliate is usually the customer facing business. It deals with the public, collects the customer’s instruction, and often takes payment. The transfer is then processed through the network provider’s rails and technology.
Why affiliates matter in Australia’s AML CTF regime
Affiliate models are attractive because they scale quickly. They also create a real compliance risk if responsibilities are unclear. Criminals look for the weak point in the chain, for example the outlet with poor onboarding, the agent with weak record keeping, or the franchise with limited training.
AUSTRAC’s reform messaging reinforces this point. The AML CTF Amendment Act 2024 strengthens Australia’s regime so it can better deter, detect, and disrupt money laundering and terrorism financing, including by expanding coverage to high risk Tranche 2 services and modernising expectations.
Even if you are not a remitter, Tranche 2 businesses can learn from the affiliate concept because many Tranche 2 operating models rely on third parties, introducers, networks, or multi site practices. The lesson is simple. Tools and branding can be centralised, but accountability for AML CTF compliance must remain clear and effective.
How an affiliate model works in practice
A typical affiliate set up has three moving parts.
Customer interface: The affiliate meets the customer, collects identification, and receives the instruction.
Network platform: The network provider supplies the systems, settlement capability, and sometimes monitoring tools.
Delivery endpoint: The recipient receives funds through another institution or agent in the destination location.
This creates shared workflows. Shared workflows are fine, but only if you can evidence who did what, when, and why.
Practical Examples
Legal references and regulatory anchors
AUSTRAC glossary definition for affiliate of a remittance network provider.
AUSTRAC points to AML CTF Act 2006 section 75C for this term.
AUSTRAC reform hub and guidance approach, which explains AUSTRAC’s interpretation of the Act and Rules and how it supports industry.
AUSTRAC announcement that the AML CTF Amendment Act 2024 received Royal Assent and updates the AML CTF regime.
Best practice for affiliates
Common challenges
Responsibility gaps between affiliate and network provider
Inconsistent customer due diligence between outlets
Poor quality escalation narratives because staff do not understand what is suspicious
Over reliance on the network’s systems without local governance
Concluding remarks
Affiliate models are not a problem. Unclear accountability is the problem. If you are an affiliate, your goal is to show AUSTRAC that you understand your risks, that your controls work in practice, and that you can evidence decisions. Tranche 2 Consultants can help you map responsibilities, design procedures that work across outlets, and build a compliance approach that is practical and defensible.
“Bookmakers sit at a natural convergence point for cash, speed and anonymity. AUSTRAC’s focus reflects the reality that wagering platforms can be misused as value transfer mechanisms if risk controls are not actively applied.”
