Travel rule obligations for beneficiary institutions (Reform)

Learn what the travel rule obligation is for a beneficiary institution providing the payee with the transferred value while carrying on a business. 

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If you’re a beneficiary institution this guidance will help you understand how to meet your travel rule obligations.

Information required in a transfer message

This section refers to the Act section 66(3) and the Rules sections 1–4 (definition of tracing information), 8–3, 8–4 and 8–5. 

When completing a value transfer, information about the transfer is included in a transfer message. The required details depend on the type of transfer, but typically include:  

  • payer information
  • the payee’s full name
  • tracing information

Receiving payer information 

The payer information you’ll receive depends on the type of transaction, but may include the payer’s full name and one or more of:

  • the payer’s date and place of birth
  • the payer’s full business or residential address (excluding post office boxes)
  • a unique identification number given to the payer by the ordering institution
  • a unique identifier for the payer.

Some transfer messages are not required to include this information and may be required to include other information such as a card number.

Learn more about completing different types of transfers.

Receiving the payee’s full name

You’ll typically receive the payee’s full name.

Some transfer messages are not required to include this information and may be required to include other information such as a card number.

Learn more about completing different types of transfers.

Receiving tracing information

Tracing information is information that allows you to identify where the value is going or has been sent. It can include: 

  • account numbers
  • virtual asset wallet addresses
  • unique transaction reference numbers. 

The transfer type determines the tracing information you must receive.

Tracing information will include information that allows tracing back to both the payer and the payee.

Tracing information for the payer

Tracing information relating to the payer is for:

  • value transfers from a payer’s account – information that allows you to identify the account, such as an account number
  • virtual asset transfers from custodial virtual asset wallets – information such as the destination tag/memo that allows you to identify the assets in the virtual asset wallet.
  • a virtual asset transfer from a self-hosted virtual asset wallet – the address of the virtual asset wallet.

If a transfer doesn’t fall into these categories, the ordering or intermediary institution must provide a unique transaction reference number for certain transactions. 

Tracing information for the payee

Tracing information relating to the payee is: 

  • for value transfers where deposits are into the payee’s account – information that allows you to identify the account, such as an account number
  • for virtual asset transfers into a payee’s custodial virtual asset wallet – information such as the destination tag/memo that allows you to identify the payer’s virtual asset holdings
  • for virtual asset transfers into a payee’s self-hosted wallet – the virtual asset wallet address
  • in other cases – a unique transaction reference number assigned to the transfer.

Receiving card information 

If the transfer is a merchant payment or a refund of a merchant payment, the ordering institution and any intermediary institutions must pass on the card number to you.

Missing or inaccurate information

This section refers to the Act sections 65(2) and 66A(10) and the Rules sections 5–18(2), 8–4.

Find out what to do if you’re missing or have inaccurate information in your transfer messages.

Missing information

You must take reasonable steps to monitor for transfer messages missing information. You must do this by taking a risk-based approach. 

You don’t necessarily need to monitor each individual transfer message, unless it relates to a transfer of virtual assets. For example, you may complete post-event monitoring, or real-time monitoring where feasible.

You’ll define your risk-based approach in your anti-money laundering and counter-terrorism financing (AML/CTF) policies. This approach must be appropriate to the nature, size and complexity of your business, your risk profile, and must appropriately manage and mitigate the money laundering, terrorism financing and proliferation financing risks you face (we refer to these as ML/TF risks). Your AML/CTF policies must define how you’ll monitor for missing information and whether to make the value available to the payee when this happens.

For example, you may determine that you’ll monitor for missing information by sampling transfer messages and completing other assurance activities. 

You generally must receive the required travel rule information before you make available transferred virtual assets.

Inaccurate information

You must also take reasonable steps to monitor for inaccurate information about the payee. You must do this by implementing AML/CTF policies that appropriately mitigate and manage the ML/TF risk you face in providing designated services as a beneficiary institution. Depending on your business, you may complete post-event monitoring, or real-time monitoring where appropriate.

In these cases, we recommend you complete risk-based reviews of transfer messages to identify information about the payee that appears to be incorrect. For example, it’s possible that a transfer message using a fanciful name for the payee such as Homer Simpson is incorrect.

What to do if a transfer message has missing or inaccurate information

If a transfer message contains missing or inaccurate information, you must do at least one of the following:

  • reject the transfer
  • take any other risk-based actions described in your AML/CTF policies to reduce risk. 

If you receive a transfer message relating to the transfer of virtual assets, you must receive, or otherwise obtain, the payer information, tracing information and the payee’s full name before making the virtual assets available to your customer. The only exceptions to this are if you both:

  • establish on reasonable grounds that the ordering institution or an intermediary institution isn’t capable of passing on the information securely, and
  • identify, assess, mitigate and manage the ML/TF risk of making the virtual assets available, in accordance with your AML/CTF program.

This first requirement is an objective test. This exception isn’t available when another institution passing the required information to you is simply inconvenient or may cause delays. This exception may be available where the beneficiary institution has confirmed the ordering institution: 

  • isn’t required by the laws of the country it operates in to comply with the travel rule
  • hasn’t, in practice, implemented any system to securely pass on travel rule information and is unable to do so for a given transfer.

We expect that you’ll document the reasonable grounds that established the ordering or intermediary institution wasn’t capable of passing on the information securely.

Deciding not to make value available to a payee

This section refers to the Act sections 65(3) and 235.

You may decline to make value available when a transfer message is missing information or includes inaccurate information. You must decline to make value available when either:

  • the value transferred is virtual assets
  • doing so would contravene targeted financial sanctions. 

The Act gives you protections against legal proceedings in these circumstances.

Transition to new global travel rule standards

This section refers to the Rules section 8–6.

In June 2025, the Financial Action Task Force (FATF) updated recommendation 16.

Learn more about the updated recommendation in transition to new global travel rule standards.

Travel rule policies

This section refers to the Rules section 5-18.

As a beneficiary institution you must have policies that describe how you’ll:

  • take reasonable steps to monitor that you’ve received all required information
  • take reasonable steps to monitor that the information you receive about the payee is accurate
  • decide whether to make value available to the payee if you’ve received incomplete or inaccurate information
  • decide whether to request further information from other businesses in the transfer chain as part of your risk-based actions.

Beneficiary institutions that provide merchant payment services must also have policies that allow it to provide relevant information to other institutions in a value transfer chain within three business days.

You must also have systems, procedures and controls that will support you with meeting your travel rule obligations. There’s additional guidance on developing and maintaining your AML/CTF policies.

Record keeping

This section refers to the Act sections 107, 111 and 116.

You must make and keep records of individual transactions related to the value transfer services you provide. You must also keep records of your AML/CTF policies and records that demonstrate that you’ve met your travel rule obligations. 

Learn more about record keeping.

Completing different types of transfers

This section refers to the Rules section 8-4.

The actions you need to take when completing a value transfer will depend on the type of transfer. 

The following table provides guidance on these actions for beneficiary institutions. 

Learn more about:

Type of transfer What to do as a beneficiary institution
Default position for value transfers (unless conditions below apply)
  • Take reasonable steps to monitor that you’ve received the payer’s information, the payee’s full name and tracing information
  • Take reasonable steps to monitor that the information you receive about the payee is accurate
  • Reject the transfer or apply your AML/CTF policies if information is missing or inaccurate
  • Make value available to the payee in accordance with your AML/CTF policies
  • Make and keep records
Domestic value transfers received using the Bulk Electronic Clearing System BPAY or Direct Electronic Funds Transfer (DEFT)
  • Take reasonable steps to monitor that you’ve received tracing information
  • Take reasonable steps to monitor that the tracing information is accurate
  • Reject the transfer or apply your AML/CTF policies if information is missing or inaccurate
  • Make value available to the payee in accordance with your AML/CTF policies.
  • Make and keep records
Multiple transfers of value from the payer where the transfers are not domestic transfers and not received using BECS, BPAY or DEFT
  • Take reasonable steps to monitor that you receive the payer information and for each transfer of value the tracing information and the payee’s full name
  • Reject the transfer or apply your AML/CTF policies if information is missing or inaccurate
  • Make value available to the payee in accordance with your AML/CTF policies
  • Make and keep records
A merchant payment
  • Take reasonable steps to monitor that you’ve received the card number
  • Reject the transfer or apply your AML/CTF policies if information is missing or inaccurate
  • Make value available to the payee in accordance with your AML/CTF policies
  • Make and keep records
Refunding a merchant payment
  • Take reasonable steps to monitor that you’ve received the card number
  • Reject the transfer or apply your AML/CTF policies if information is missing
  • Make value available to the payee in accordance with your AML/CTF policies
  • Make and keep records
Transfers that are ATM withdrawals
  • Take reasonable steps to monitor for receipt of the card number used for the withdrawal
  • Reject the transfer or apply your AML/CTF policies if information is missing
  • Make value available to the payee in accordance with your AML/CTF policies
  • Make and keep records
A transfer where money moves into Australia from overseas and the beneficiary institution receives the transfer message through the Bulk Electronic Clearing System
  • Take reasonable steps to monitor that you’ve received the tracing information
  • Reject the transfer or apply your AML/CTF policies if information is missing or inaccurate
  • Make value available to the payee in accordance with your AML/CTF policies
  • Make and keep records
A value transfer from a self-hosted virtual asset wallet
  • Obtain payer and payee information, for example from the payee (your customer)
  • Reject the transfer if you’re unable to obtain payer information, the payee’s full name and tracing information
  • Make value available if you’ve obtained payer information, the payee’s full name and tracing information
  • Make and keep records

This guidance sets out how we interpret the Act, along with associated Rules and regulations. Australian courts are ultimately responsible for interpreting these laws and determining if any provisions of these laws are contravened. 

The examples and scenarios in this guidance are meant to help explain our interpretation of these laws. They’re not exhaustive or meant to cover every possible scenario.

This guidance provides general information and isn't a substitute for legal advice. This guidance avoids legal language wherever possible and it might include generalisations about the application of the law. Some provisions of the law referred to have exceptions or important qualifications. In most cases your particular circumstances must be taken into account when determining how the law applies to you.

Last updated: 15 Oct 2025
Page ID: 1353

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