On 12 June 2019, AUSTRAC ordered the appointment of an external auditor to Afterpay Australia Pty Ltd (Afterpay) to examine its compliance with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (the AML/CTF Act).

In response to the findings and recommendations identified in the external audit report, Afterpay has uplifted its AML/CTF compliance framework and financial crime function, and completed all remediation necessary to ensure compliance.

After considering the report and the response by Afterpay, AUSTRAC has decided not to undertake further regulatory action.

AUSTRAC has reiterated the importance for Afterpay to meet its compliance obligations in the future, and will continue to work with Afterpay to ensure they understand their compliance obligations and role in fighting financial crime to protect the Australian community from harm.

It is also a reminder to new and emerging financial services businesses that they may have obligations under the AML/CTF Act.  

Start-up ventures and technology-based financial businesses must consider whether they have AML/CTF obligations and if they do put in place systems and controls that identify and mitigate money laundering and terrorism financing risks.