1. Our commitment
SGCPAY (AUS) LIMITED (ABN 61 662 299 434) ("SGCPAY", "we", "us" or "our") is committed to preventing money laundering, terrorism financing, and other financial crime. We take our obligations under Australia's anti-money-laundering and counter-terrorism-financing (AML/CTF) regime seriously and maintain policies, procedures, and controls designed to meet them.
This statement provides a general overview of our approach. It is not a complete description of our internal program and should be read together with our Terms and Conditions, Acceptable Use Policy, and Privacy Policy.
2. Regulatory framework and registration
We are registered with the Australian Transaction Reports and Analysis Centre (AUSTRAC), Australia's AML/CTF regulator and financial intelligence agency. We are registered on the Digital Currency Exchange (Virtual Asset Service Provider) Register, registration number DCE100840582-001, and on the Remittance Service Provider Register, registration number IND100840582-001.
Our AML/CTF program is designed to be consistent with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and associated rules, as applicable to the services we provide.
3. Customer due diligence
Before providing designated services, we carry out customer due diligence, which includes verifying the identity of our customers and, for business customers, identifying beneficial owners and relevant officers. We may request identification documents and other information, and we may be unable to provide services until verification is complete.
We apply enhanced due diligence where a customer, transaction, or relationship presents a higher risk, and we conduct ongoing due diligence throughout the customer relationship.
4. Sanctions and screening
We screen customers and, where appropriate, transactions against applicable sanctions lists and against politically-exposed-person and adverse-media sources. We do not provide services where doing so would breach applicable sanctions, and we may decline, delay, or reverse transactions on this basis.
You must not use our services in a way that would cause us to breach sanctions, as set out in our Acceptable Use Policy.
5. Transaction monitoring
We monitor activity for indicators of money laundering, terrorism financing, fraud, and other financial crime. Where activity is unusual or inconsistent with what we know about a customer, we may seek further information, apply restrictions, or take other appropriate action.
Monitoring is an ongoing process and applies throughout the life of the customer relationship.
6. Reporting obligations
Where required by law, we submit reports to AUSTRAC, which may include suspicious matter reports, threshold transaction reports, and other regulatory reporting. We are generally prohibited by law from disclosing, or "tipping off," that a suspicious matter report has been or may be made.
Meeting these obligations may require us to delay, decline, or restrict a transaction, and we may be unable to explain our reasons in specific cases where the law prevents us from doing so.
7. Record-keeping
We keep records relating to customer identification, transactions, and our AML/CTF program for the periods required by law. These records are handled in accordance with our Privacy Policy and are retained even after a customer relationship ends, for as long as the law requires.
We treat this information as confidential and use it for compliance, legal, and record-keeping purposes.
8. Governance and training
Our AML/CTF program includes governance and oversight arrangements, risk assessment, and staff training appropriate to the services we provide. We review and update our program from time to time to reflect changes in our business, in risk, and in legal and regulatory requirements.
Registration with AUSTRAC relates to these obligations and does not constitute an endorsement of SGCPAY or a guarantee in relation to any particular service.
9. Your responsibilities and contact
You must cooperate with our compliance requests, provide accurate information, and use our services only for lawful purposes, as described in our Acceptable Use Policy. Failure to do so may result in restrictions on, or termination of, your access.
If you have questions about this statement, or wish to report a concern, you can contact us via the contact form on our website. The current version of this statement is the version published on our website, and the "Last updated" date indicates when it last changed.