Agent guide

Anti-Money Laundering & Counter Terrorist Financing

ABN: 70 631 043 966

ACN: 631 043 966


Table of contents


Tawkal Sii Pty Ltd is committed to the highest standards of legality and ethics, enforcing rigorous compliance measures to thwart money laundering and terrorist financing. This guide, crafted by Tawkal Sii Pty Ltd, aims to familiarize its remittance affiliates with the Australian legal framework, particularly laws targeting the misuse of financial services for criminal activities. Each affiliate is bound by a contractual agreement with Tawkal Sii Pty Ltd, outlining their responsibilities and compliance obligations.

Affiliates are strictly forbidden from participating in or advising on money laundering and counter-terrorism activities. They are mandated to:

• Vigilantly identify any customer transactions suggestive of money laundering or related criminal acts like drug trafficking.

• Collaborate with legal authorities as per the law.

As an affiliate of Tawkal Sii Pty Ltd, you are required to thoroughly review this guide. Violations of these guidelines, whether accidental or deliberate, could lead to termination of your association with Tawkal Sii Pty Ltd and may also attract legal penalties.

Legal Disclaimer

This document is for informational purposes and should not be considered as legal advice. For specific legal counsel, particularly regarding the interpretation and application of laws, it’s advisable to consult a lawyer.

Civil and Criminal Sanctions

Breaching the AML/CTF Act carries significant risks, including loss of reputation, legal repercussions, and both civil and criminal penalties. Those involved with Tawakal Sii Pty Ltd.’s money transfer services need to be aware that they could face liability for ignoring or failing to recognize suspicious activities.

Purpose of this Document

Tawakal Sii Pty Ltd is dedicated to preventing money laundering and terrorist financing. This involves conducting thorough due diligence on all Agents and Correspondents before engagement. Tawakal Sii Pty Ltd ensures that all remittances are monitored to prevent illegal activities. We adhere strictly to Australian laws and regulations, and international sanctions from entities like OFAC, DFAT, the European Union, and the United Nations.

This Compliance Manual serves as a guideline, illustrating our policies and the legal framework designed to fight money laundering and terrorist financing.

Tawakal Sii Pty Ltd Agents

This Compliance Manual is part of your policy framework but might need to be tailored to fit your unique business requirements. It is designed as a training resource for new employees and should be included in ongoing training initiatives. All Agents involved in processing transactions for Tawakal Sii Pty Ltd must have access to and understand this manual.

Agents are obligated to appoint an AML/CTF Compliance Officer, responsible for administering the Anti-Money Laundering and Counter-Terrorism Financing Program in line with the AML/CTF Act of 2006, the Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument (2007) No.1, the Privacy Act 2014, the Australia Privacy Principles, DFAT regulations, and OFAC standards.

Money Laundering

Definition and Legal Framework:

Money laundering, as defined in section 5 of the AML/CTF Act and Division 400 of the Criminal Code Act 1995, essentially involves criminals concealing the origin and ownership of proceeds from their illegal activities to avoid legal consequences. This process generally consists of three phases: placement, layering, and integration.

Understanding the Process:

Agents need to grasp how money laundering is carried out to effectively identify potential signs of it. Criminals use financial institutions and various services to obscure the origin of illegally obtained profits, often by conducting transactions that bypass legal reporting thresholds.

The Three Stages of Money Laundering:

1. Placement:

This initial step introduces illicit funds into the financial system, making them more fluid. Techniques include:

• “Structuring,” or breaking down large cash sums into smaller, less conspicuous deposits.

• Cross-border cash shipments for deposit in overseas banks or buying assets like art or precious metals for later resale.

• “Smurfing,” where multiple people deposit illicit cash across several banks in one day.

• Converting cash into travellers’ checks, food stamps, or other monetary instruments for deposit.

• Buying goods and services, later returned for a refund in a more ‘clean’ form.

2. Layering:

In this phase, the funds are distanced from their illegal source through complex, often international, financial transactions to obscure their trail. Techniques include:

• Funds transfers via checks or electronic transfers.

• Converting cash into other forms, like travellers’ checks, and reselling them.

• Investing in real estate or businesses.

• Shuffling funds across multiple accounts and countries, using remittance services, banks, and intermediary professionals.

3. Integration:

The final stage reintroduces the laundered money into the economy as seemingly legitimate funds, now distant from their criminal origins. This can be done through:

• Manipulating business receipts or invoices.

• Establishing front companies or fake charities.

• Trading in gold bullion: buying with illegal funds and selling to regain cash.

Common Methods of Money Laundering

Purchasing Assets with Cash:

This method involves buying expensive items like cars, boats, or property with cash. The assets are often registered under someone else’s name, like a friend or relative, to conceal ownership. They might be sold later for further money laundering.

Black-Market Peso Exchange:

This is a scheme where money from illegal activities in Australia is bought by Colombian peso brokers. These brokers deposit the money in Australian bank accounts they control. They then provide checks and wire transfers from these accounts to legitimate businesses for buying goods and services in Australia.

Cuckoo Smurfing:

Here, criminals swap legitimate funds destined for Australian bank accounts with crime proceeds. The original funds are then used elsewhere.

Currency Smuggling:

Moving funds across borders to hide their origin and ownership, avoiding record-keeping rules. This involves hiding money in personal items or containers and often sending it to countries with strict bank secrecy.

Exchange Transactions:

Using crime proceeds to buy foreign currency, which is then transferred to offshore accounts.

Casino Gambling:

Criminals use cash from illegal sources to buy casino chips, gamble minimally, and then cash out with a casino cheque, making the money appear legitimate.

Using Nominees:

Conducting transactions through other people, often trusted family members or friends, to hide the true source and ownership of funds.


Exchanging small bills for larger ones at banks, casinos, or money service businesses, to reduce the bulk and arouse less suspicion.

Reverse Flip in Real Estate:

A launderer buys property for significantly less than its value, with the seller agreeing to receive the difference secretly. The property is then sold later at its actual value.


Breaking up transactions to evade reporting requirements. This could be transferring money in amounts below a threshold over multiple days or conducting multiple transactions at different locations to circumvent reporting rules.


Multiple individuals (smurfs) deposit cash, buy money transfers, or bank drafts at various financial institutions. The funds are then gathered into a central account, with each transaction being small enough to avoid detection.

Manipulating Import/Export Prices:

Overpricing exports to move funds out of a country, or under-pricing imports to bring money in. For instance, a company might pay an inflated price for an overseas product, providing a facade for moving or laundering money.

Terrorism Financing

Definition and Legal Background:

Terrorism financing is defined in section 5 of the AML/CTF Act and Division 103 of the Criminal Code Act 1995. It encompasses funding terrorist acts, terrorists, and their organizations. It involves the provision or collection of funds with reckless disregard of their use in terrorist activities.

The Nature of Terrorism Financing:

Terrorists require financial support for their activities and objectives, similar to other criminal entities in their financial system usage. Effective terrorist groups build a robust financial infrastructure, sourcing funds and obscuring their connection to terrorist activities. The funds for terrorism aren’t always from illegal activities; they may come from legal fundraising too. The funds, used for ordinary expenses and terrorist acts, don’t need to be large or involve complex transactions.

Operation and Financing:

Terrorist operations typically require modest funds. For example, the World Trade Centre and Pentagon attacks cost about $500,000. Terrorist financiers need to transfer relatively small amounts to terrorist cells. Funding may come from illicit activities and legal fundraising, where donors might be unaware of the true use of their contributions. This makes tracking terrorist financing challenging.

Terrorists differ from traditional criminal groups in their use of social and religious organizations and, occasionally, state sponsorship for funding. Larger organizational costs for recruitment, training, and operations often lead terrorists to use proceeds from traditional crimes like kidnapping, narcotics trafficking, and fraud.

Methods of Moving Funds:

Terrorists and traffickers use both formal financial sectors and informal methods. Common techniques include cash, gem, or precious metal smuggling and reliance on money changers. In countries with currency controls and cash-based economies, these changers are crucial for fund transfers, often used by expatriates for remittances. Terrorists also use systems like “hawala” or “hundi” for paperless fund transfers.

Trade-Based Laundering:

Both crime groups and terrorists use trade-based laundering, manipulating trade to move funds. This includes the Black-Market Peso Exchange, gold trading in the Middle East, and gem trading in Africa.

Comparative Overview:

• Money Laundering vs. Terrorist Financing:

o Money laundering is profit-motivated, while terrorist financing is ideologically driven.

o Money launderers prefer the formal financial system; terrorists opt for cash couriers or informal systems.

• Detection in money laundering focuses on suspicious transactions, whereas in terrorist financing, it’s on suspicious relationships.

• Money laundering involves large, often structured transactions, while terrorist financing uses small amounts below thresholds.

• The financial activity in money laundering is complex, involving shell companies and offshore accounts. In contrast, there’s no consistent financial profile for operational terrorists.

• The money trail in laundering is circular, returning to the originator, while in terrorism, it’s linear, funding the group and its activities.

Overview of Money Laundering and Terrorist Financing Regulations

The AML/CTF Act’s Introduction and Objectives:

Australia’s AML/CTF Act, effective from 12 December 2006, is part of the country’s initiative to overhaul its anti-money laundering and counter-terrorism financing (AML/CTF) framework. The Act’s key goals include:

• Facilitating international business for the Australian financial sector.

• Aiding the detection and prevention of money laundering and terrorist financing.

• Aligning with global standards set by the Financial Action Task Force (FATF).

Scope and Coverage:

The AML/CTF Act encompasses the financial and gambling sectors, bullion dealers, and other entities offering specific services like designated remittances.

Mandatory Obligations:

Entities providing these designated services must adhere to several requirements, including:

• Implementing an extensive AML/CTF program, covering customer identification, ongoing due diligence, staff training, record-keeping, and compliance oversight.

• Appointing a dedicated AML/CTF Compliance Officer.

• Periodically conducting independent reviews of their AML/CTF program.

• Registering as a designated remittance network or service.

• Submitting AML/CTF Compliance Reports.

• Fulfilling various reporting duties, like Suspicious Matters Reports and Threshold Transaction Reports for transactions over $10,000 AUD.

Risk-Based Approach:

The Act promotes a risk-based regulatory approach, allowing entities to tailor their compliance strategies based on the perceived risk of facilitating money laundering or terrorism financing through their services.


AUSTRAC continues as Australia’s financial intelligence unit and expands its role as the national AML/CTF regulator, overseeing a wide array of business sectors.

Designated Services and Reporting Entities:

The Act categorizes ‘designated services’ into financial services, bullion, gambling, and other prescribed services. Providers of these services are classified as ‘reporting entities.’

Remittance Services:

Remittance services, involving transferring money or property, especially across borders, are identified as financial services. Entities like Tawakal Sii Pty Ltd, operating remittance networks, must be registered with AUSTRAC. Similarly, agents using these networks for remittance services are also considered independent reporting entities and must be registered accordingly. Tawakal Sii Pty Ltd.’s contracts with these agents outline their AML/CTF obligations, and unregistered agents are prohibited from using Tawakal Sii Pty Ltd.’s network for remittance services.

AML/CTF Compliance Program

Program Requirements:

Under the AML/CTF Act, designated service providers like Tawakal Sii are mandated to establish and maintain an AML/CTF program. This program is divided into Part A, focusing on overall risk management, and Part B, which addresses customer identification.

Agent Compliance:

Agents are required to adhere to an AML/CTF program that complies with the AML/CTF Act when providing remittance services through Tawakal Sii’s network. While many agents adopt Tawakal Sii’s AML/CTF program, changes to this program require Tawakal Sii’s prior approval. Agents also have the option to develop their own AML/CTF program, subject to Tawakal Sii’s approval.

Program Structure:

Part A is aimed at identifying, mitigating, and managing potential risks of money laundering and terrorism financing associated with providing designated services. This involves:

• Identifying potential risks.

• Analysing and prioritizing risks to develop mitigation strategies.

• Continuously monitoring and reviewing these strategies.

Part B sets out required procedures for customer identification and verification.

AML/CTF Compliance Officer Appointment:

Tawakal Sii’s Board of Directors appoints an AML/CTF Compliance Officer to oversee the AML/CTF Compliance Program. This officer has:

• Broad access to all business areas and staff.

• Authority to implement corrective actions.

The Compliance Officer at Tawakal Sii can be reached at:

Suite 10, 22-24 Auburn Road, Auburn NSW 2144, Australia


Agents must appoint their own Compliance Officer with similar responsibilities, including:

• Coordination with Tawakal Sii’s AML/CTF Compliance Officer.

• Ensuring adherence to the AML/CTF program and compliance manual.

• Managing AUSTRAC-related activities and compliance with Customer Identification and Due Diligence Procedures.

AUSTRAC’s Role and Public Awareness:

AUSTRAC publicizes its activities, including enforcement actions, to raise awareness about AML/CTF compliance. Responses to AUSTRAC requests should be prioritized, with all related communications reported to Tawakal Sii’s AML/CTF Compliance Officer.

Reporting Obligations


As per the agency agreement and with the approval of the Tawakal Sii Pty Ltd AML/CTF Compliance Officer, Tawakal Sii Pty Ltd directly manages all reporting duties to AUSTRAC. These obligations include:

AML/CTF Compliance Report:

According to subsection 47(2) of the AML/CTF Act, a reporting entity must annually submit an AML/CTF Compliance Report to AUSTRAC. The Tawakal Sii Pty Ltd AML/CTF Compliance Officer is tasked with preparing and submitting this report by the designated due date, currently set as 31st March.

Suspicious Matter Reports (SMRs):

Section 41 of the AML/CTF Act mandates reporting entities like Tawakal Sii Pty Ltd and its Agents to report suspicious matters to AUSTRAC. Agents are required to notify Tawakal Sii Pty Ltd of any unusual or suspicious activities. If the suspicion involves terrorism financing, it must be reported to AUSTRAC within 24 hours. For other cases, it should be within three business days.

The reporting process involves:

• Providing reasons for the suspicion.

• Detailing the nature and context of the matter.

• Identifying the likely offense related to the suspicion.

Agents report suspicious activities by filling out a specific form on the transaction page of the online platform. The completed form, along with transaction details, is sent to Tawakal Sii Pty Ltd.’s Compliance Department for further review and action.

Indicators of Suspicious Behaviour:

Suspicious behaviours include but are not limited to:

Counterfeit or false ID presentation.

• Reluctance to provide required documents.

• Vague responses regarding source of funds.

Structuring transactions to avoid reporting thresholds.

• Sudden increase in transaction frequency or amount.

• Unusual customer profiles or transaction patterns.

• Complex or disproportionate source of funds.

• Nervous or evasive behaviour during transactions.

Tipping Off:

Tawakal Sii Pty Ltd and its Agents must not disclose that an SMR has been submitted. This ‘tipping off’ is prohibited by the AML/CTF Act, with penalties including imprisonment. However, this does not apply to legal consultations or disclosures under law, including those related to sanctions lists or law enforcement communications.

International Funds Transfer Instruction Report (IFTI):

Section 46 of the AML/CTF Act outlines the reporting requirements for IFTIs. Tawakal Sii Pty Ltd.’s Compliance Department is responsible for reporting all IFTIs to AUSTRAC electronically within 10 days of the instruction date.

Threshold Transaction Report (TTR):

Section 43 of the AML/CTF Act details the obligations for reporting threshold transactions. Transactions involving AUD10,000 or more must be reported to AUSTRAC within 10 days of occurrence. Tawakal Sii Pty Ltd.’s Compliance Department ensures all such transactions are reported timely.

aML/TF Risk Assessment Program and Agent’s Compliance with Tawakal Sii Pty Ltd.’s Guidelines

Under the AML/CTF Act and its associated rules, systems and controls must be implemented by businesses to manage ML/TF risks. While these regulations do not prescribe a specific method for risk management, Tawakal Sii Pty Ltd, considering its size, nature, and complexity, is ideally positioned to evaluate the ML/TF risks in offering designated services.

As reporting entities, agents of Tawakal Sii Pty Ltd are required to adhere to and implement the risk-based systems, controls, and mitigation strategies developed by Tawakal Sii Pty Ltd.

Agents must be aware of Tawakal Sii Pty Ltd.’s guidelines in key areas of risk assessment:

Customer Risk:

Agents need to evaluate customer risks, including the expected customer profile, transaction purposes, relationships with beneficiaries, sources of funds, and occupation, following the criteria set by Tawakal Sii Pty Ltd.

Products and Channel:

Agents are obligated to assess the inherent risks involved in their money transfer services, following the guidelines provided by Tawakal Sii Pty Ltd. Moreover, they are restricted to conducting transactions exclusively in a face-to-face manner, in compliance with the operational protocols set by Tawakal Sii Pty Ltd.

Jurisdiction Risk:

Agents should assess risks associated with the countries where transactions occur and the areas where their premises are located, in accordance with Tawakal Sii Pty Ltd.’s standards.

Internal Risk:

The size of the agent’s company, its business structure, employee numbers, and transaction volume should be assessed in line with Tawakal Sii Pty Ltd.’s risk assessment framework.

Agents should rely on Tawakal Sii Pty Ltd.’s policies. It’s crucial for agents to intensify surveillance and due diligence for higher risk customers or transactions. This includes requesting additional information, posing further questions when necessary, and reporting suspicious transactions in line with Tawakal Sii Pty Ltd.’s risk assessment guidelines.

Know Your Customer (KYC)

Know Your Customer (KYC) is a due diligence initiative aimed at identifying customers and monitoring their transactions to comply with legal standards and prevent money laundering or terrorist financing. Tawakal Sii Pty Ltd classifies “customers” as individuals purchasing money transfer products and “Agents” as affiliates selling them.

The main goals of the KYC policy include:

• Only accepting legitimate customers.

• Properly identifying customers to assess associated risks.

• Verifying customer identities using reliable, independent sources.

Monitoring accounts to prevent or detect illegal activities.

• Managing risks of misuse of Agent facilities effectively.

Customer Acceptance Policy:

Tawakal Sii Pty Ltd prohibits anonymous or fictitious name accounts and does not service customers below 18 years old. Transactions or business relationships commence only after thorough customer due diligence (CDD) measures, including ID verification and customer registration in the system.

Transactions must not proceed if CDD requirements are unmet. Staff should report any suspicious activities immediately. Tawakal Sii Pty Ltd allows transactions only for individual customers, not for ‘on behalf of’ transactions. It does not process transactions to or from Iran or North Korea due to Australian Government regulations.

Customer Due Diligence:

Tawakal Sii Pty Ltd mainly targets second-generation immigrants for family remittances. Unless indicated otherwise, the customer is presumed to be the beneficial owner. Required information includes full names, ID details, residential address, phone number, occupation, relationship with the beneficiary, and reasons for transfer.

Agents must verify the customer’s identity against their ID for all transactions. Acceptable IDs include driver’s license, passport, proof of age card, national identity card, or refugee travel document.

Ongoing Customer Due Diligence:

Tawakal Sii Pty Ltd ensures regular review and update of customer information. Agents are also responsible for maintaining current customer data. Continuous monitoring of customers and transactions is vital, especially for those posing higher ML/TF risks.

Enhanced Customer Due Diligence:

Agents should adapt their due diligence measures based on changes in customers’ ML/TF risk profiles. Enhanced due diligence, including additional checks and information gathering, is essential for customers presenting higher risks.

Customer Screening:

For sanctions screening and PEP checks, Tawakal Sii Pty Ltd employs services like GreenID and BronID. These tools are used for verifying customers against international sanctions lists and PEP databases. Transactions are paused for further review if potential matches are found, with the Compliance Department managing the review and decision-making. Enhanced due diligence is required for transactions involving identified PEPs.

Transaction Monitoring Program and Financial Investigation Program

Tawakal Sii Pty Ltd has established a comprehensive Transaction Monitoring Program (Real-time) and Financial Investigation Program (Post-transactional), specifically tailored to its risk profile. These programs are designed to meet Customer Due Diligence requirements and to detect transactions that potentially involve money laundering or terrorist financing.

These programs are reviewed annually to ensure alignment with the mitigating controls in the ML/TF Risk Assessment, and to stay current with evolving ML/TF trends and changes in the AML/CTF regulatory framework.

Key elements of Tawakal Sii Pty Ltd.’s Real-Time Transaction Monitoring Program include:

Monitoring of transaction amounts for large or unusual transfers.

• Analysis of transaction frequency to spot abnormal patterns.

• Reviewing transactions for country-specific risks.

Sanctions checks against entities or individuals.

• Conducting Politically Exposed Person (PEP) checks to identify high-risk profiles.

Additionally, the Post-Transaction Monitoring aspect of Tawakal Sii Pty Ltd.’s Financial Investigation Program incorporates:

• Advanced analytical tools for thorough examination of completed transactions.

• Gathering information through referrals from employees, Agents, and Correspondents.

In this Post-Transaction Monitoring phase, a specific tool is employed to conduct transaction analysis, aggregating data by agent, country, or corridor. Analysts extract reports with relevant data sets for analysis, inputting them into a specialized macro. This macro processes the data and creates alerts based on suspicious patterns such as:

• Many-to-one and one-to-many transactions.

• Customers engaging in transactions to/from multiple countries.

• Related customers from various nationalities.

• Signs of structuring, smurfing, and use of money mules.

• Unusual behaviours, high-velocity transactions, or indicators of fraud.

This approach is integral to Tawakal Sii Pty Ltd.’s strategy in identifying and managing potential risks associated with money laundering, terrorist financing, and fraudulent activities within its operations.

Know Your Agent Policy of Tawakal Sii Pty Ltd

Tawakal Sii Pty Ltd diligently upholds robust due diligence processes in compliance with AML/CTF regulations through its “Know Your Agent” policy. This critical policy ensures that all affiliates, or agents, are rigorously vetted prior to their access to the network. The policy includes several key elements to verify and maintain accurate records:

Company Information Verification:

• Full Registered Name: Verifying the legal name of the affiliate company.

• ABN or Unique Registration/Identification Number: Confirming the company’s registration number.

• Registered or Principal Address: Establishing the company’s official or main operating address.

Beneficial Owner Details:

• Name: Obtaining the full name of the beneficial owner(s).

• Date of Birth: Confirming the birth date of the beneficial owner.

• Residential Address: Verifying the beneficial owner’s residential address.

Verification of Information:

• Tawakal Sii Pty Ltd complies with the AML/CTF Act 2006 and AML/CTF Rules in verifying information from affiliates, combining:

o Citing originals and taking certified copies of documents, or

o Collecting certified copies of documents, such as those certified by a Justice of the Peace.

Additionally, under the AML/CTF Act and Rules, Tawakal Sii Pty Ltd requires agents to notify any material changes regarding their registration or business and key personnel details within 3 days. These notifiable changes include:

• Changes in business address, email, phone, and fax numbers.

• Changes in the agent’s legal or trading name.

• Addition or removal of key personnel.

• Changes in key personnel’s residential address, phone number, and name.

• Situations where the business or key personnel are charged, prosecuted, convicted, or subject to civil penalty orders under the AML/CTF Act, or involved in civil/criminal proceedings or enforcement actions.

Under the Agent Agreement, agents must also inform Tawakal Sii Pty Ltd in writing about any changes to their financial situation or events that could materially affect their business operations or ability to perform their duties within 3 business days of the event.

This comprehensive policy ensures that Tawakal Sii Pty Ltd engages with thoroughly vetted, legitimate, and compliant agents, safeguarding the integrity of its operations and minimizing the risk of ML/TF activities.

Employee Screening/ Guideline for Agent

Conduct Comprehensive Background Checks:

Agents must perform thorough background checks on all potential employees. This includes assessing criminal history and financial stability, such as through bankruptcy searches.

Verify References:

Reach out to previous employers and references provided by the candidate. Verify the applicant’s work history, qualifications, and character.

Document Verification:

Validate the identity of candidates using official documents like passports, driver’s licenses, or national ID cards. Ensure these documents are original, valid, and unaltered.

Role-Specific Assessments:

Tailor your screening process according to the specific role. For positions with financial responsibilities, conduct detailed financial background checks. Verify any necessary qualifications or certifications for the role.

Risk Assessment for High-Risk Roles:

For positions that have a greater potential of being involved in ML/TF activities, implement an enhanced screening process. This includes deeper background checks and closer scrutiny of the candidate’s professional history.

As an agent, it is your responsibility to ensure that these screening steps are diligently followed. This process is crucial not only for compliance with AML/CTF regulations but also for maintaining the integrity and security of our operations. Keep detailed records of all screening procedures and outcomes and ensure that these practices are in line with legal and privacy standards. Remember, effective employee screening is a critical defence against potential risks and malpractices in our industry.

Compliance Training

During the setup process for new Agents, Tawakal Sii Pty Ltd.’s Account Manager is responsible for providing each Agent with a copy of the compliance manual. This manual serves as a foundation for face-to-face ML/TF risk awareness training. Agents are required to complete an acknowledgement form confirming they have received and understood the compliance training. This acknowledgement is then stored in the Agent’s file. Ongoing training for Agents is conducted using a risk-based approach.

All new employees working for Agents are obligated to participate in the training courses offered by Tawakal Sii Pty Ltd. The Agent’s AML/CTF Compliance Officer is tasked with ensuring that any employee who needs further training in areas of deficiency receives it. Agents are expected to provide confirmation of completed training as stipulated by Tawakal Sii Pty Ltd from time to time.

Training Material:

The training materials are supplied by Tawakal Sii Pty Ltd. Therefore, the Agent Compliance Officer should utilize only the approved training materials.

Training Records:

Agents are required to maintain a comprehensive log of all training sessions conducted. This log should include the names of the trainer and trainees, the training materials used, the date of training, and any assessments or proofs of knowledge acquired during the training. Keeping these records is crucial for demonstrating compliance with the training requirements set forth by Tawakal Sii Pty Ltd (AUSTRAC online modules 1-4

Record Keeping

Effective record keeping is a critical component of an Agent’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) program. Agents under Tawakal Sii Pty Ltd are required to maintain a reliable record-keeping system, ensuring that all records related to their AML/CTF activities are well-organized and can be accessed quickly upon request. These records must be kept for at least seven years from the date they were created, allowing for efficient retrieval and review as needed to demonstrate compliance with AML/CTF regulations.

After this seven-year retention period, it is essential to securely destroy the records to prevent any misuse or unauthorized disclosure of sensitive information. Agents are expected to undertake this destruction process securely, typically involving professional records management services. Evidence of this process, as per legal requirements, should be readily available and provided during compliance review visits. This approach ensures both adherence to regulatory standards and the safeguarding of confidential information handled by Tawakal Sii Pty Ltd and its Agents.

Fraud Prevention:

The Fraud Prevention Guidelines for Tawakal Sii Pty Ltd emphasize the importance of agents being well-versed with the policy developed by the company. This comprehensive strategy is designed to address common fraud types in money transfer services, allocating specific responsibilities to agents, management, and security teams. Agents are particularly responsible for identifying and reporting suspicious activities, and they must be aware of various fraud schemes and adhere to procedures for preventing, detecting, and responding to fraud. Regular updates and training are vital for agents to stay informed about evolving fraud tactics. Guidelines are updated as required, Agents are encouraged to keep updated copy and familiarize themselves with it to prevent frauds.

Data Privacy

Since March 12, 2014, there have been changes to the Privacy Act. These changes include 13 Australian Privacy Principles (APPs) that apply to organizations like ours. These rules are about how we handle personal information.

As an agent of Tawakal Sii Pty Ltd, we need to follow these rules too. We collect personal info from customers through forms and transactions. We only use this info for the services they ask for, and we keep it safe.

We don’t share or sell this info. We have security measures to protect it. Everyone, including former and new customers, gets the same privacy protection.



Account 6

Advice 3

Affiliate 3, 16

Agent Agreement 17

Agents 3, 4, 10, 11, 12, 13, 14, 15, 17, 18, 19

Anti-Money Laundering 1, 4, 19

Assets 4, 5

AUSTRAC 9, 10, 11, 12, 19


Background checks 17, 18

Banks 4, 5, 6

Bills 6

Borders 6, 9


Cash 4, 5, 6, 7, 8

Cheque 6

Civil 3

Compliance 2, 3, 4, 9, 10, 11, 12, 15, 18

Compliance Officer 4, 9, 10, 11, 18

Counterfeit 12

Counter-terrorism 3, 8

Counter-Terrorism Financing 4, 19

Criminal 3, 5, 7, 17

Criminals 4, 6

Customer 2, 3, 9, 10, 12, 13, 14, 15

Customers 13, 14, 15, 16, 20


Definition 4, 7

Deposit 4, 5, 6

Disclaimer 3

Due diligence 3, 9, 13, 14, 15, 16


Financial services 3, 9

Financing 1, 4, 7, 8, 19

Foreign 6

Fraud 2, 19

Funds 4, 5, 6, 7, 8, 12, 13


Guideline 3


High-Risk 18


Identify 3, 4, 15

Illicit 4, 7

Institutions 4, 6

Integration 4, 5

Integrity 17, 18

Internal 13

Invoices 5


Know Your Agent 2, 16

Know Your Customer 2, 13

KYC 2, 13, 14


Laundering 1, 2, 4, 5, 8, 19

Law 3

Laws 3

Layering 4, 5

Legal 3, 4, 7, 12, 13, 16, 17, 18, 19

Liability 3


Money laundering 3, 4, 5, 8, 9, 10, 13, 15, 16

Monitoring 2, 14, 15


Objectives 8

Offshore accounts 6, 8

Operation 7

Origin 4, 6

Ownership 4, 5, 6


Penalties 3, 12

Phase 5, 15

Placement 4

Policy 4, 14, 16, 17, 19

Privacy 2, 4, 19, 20

Process 4

Profits 4

Program 9, 10, 19


Receipts 5

Record 2, 19

Records 18

References 17

Report 11, 14

Reporting 4, 6, 9, 11, 12, 13, 19

Reports 9, 11

Requirements 10

Responsibilities 3, 10, 18, 19

Reviews 9

Risks 3, 10, 12, 13, 14, 15, 16, 18

Rules 4, 16, 17


Sanctions 3, 12, 15

Secrecy 6

Services 3, 4, 5, 8, 9, 10, 12, 13, 15, 19, 20

Smurfing 4, 5, 6

Smurfs 6

Standards 3, 4, 8, 13, 18, 19

Structuring 4, 6, 12

Suspicion 6, 11

Suspicious 3, 8, 11, 13, 14, 15, 19


Terrorism Financing 4, 7, 19

Terrorist financing 3, 7, 8, 13, 15, 16

Training 2, 4, 7, 9, 18, 19

Transaction 6, 11, 12, 13, 15

Transactions 3, 4, 5, 6, 7, 8, 9, 12, 13, 14, 15, 16, 20

Transfer 3, 7, 13, 14, 19


Verification 16, 17

Violations 3