Travel rule obligations for intermediary institutions (Reform)
Learn what the travel rule obligation is for intermediary institutions who receive and pass on transfer messages to the next business in the value transfer chain while carrying on a business.
On this page
- Information required in a transfer message
- Monitoring for missing information in transfer messages
- What to do if a transfer message has missing information
- Passing on a transfer message
- Transition to new global travel rule standards
- Travel rule policies
- Record keeping
- Completing different types of transfers
- Related pages
An intermediary institution doesn’t accept the instruction from the payer or provide the transferred value to the payee. They only exist in a value transfer chain. This means one or more intermediary institutions can only exist between an ordering institution and a beneficiary institution.
The travel rule overview page helps businesses understand if they’re an intermediary institution. If you’re an intermediary 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 Rules sections 1–4, 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
You’ll typically receive the following payer information from the ordering institution or another intermediary institution:
- 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 payee’s full name
You’ll typically receive the payee’s full name from the ordering institution or another intermediary institution.
Some transfer messages are not required to include the payee’s full name 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 allows the ordering institution and beneficiary institution to identify where the value is going or where it has been sent from. It can include account numbers, virtual asset wallet addresses or transaction reference numbers. The transfer type determines the tracing information you’ll receive.
Tracing information will include information related to both payer and payee.
Tracing information for the payer
Tracing information relating to the payer is:
- for value transfers from a payer’s account – information that allows the ordering institution to identify the account, such as an account number
- for virtual asset transfers from custodial virtual asset wallets – information such as the virtual asset wallet address or destination tag or memo that allows the ordering institution to identify the assets in the virtual asset wallet
- for 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 institution must provide a unique transaction reference number.
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 the beneficiary institution 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 or memo that allows the beneficiary institution 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, a refund of a merchant payment or an ATM withdrawal of money, you’ll generally receive the card number. This can include a tokenised reference that allows the card issuer to trace the payment back to the payer’s card.
Monitoring for missing information in transfer messages
This section refers to the Act section 66(2).
You must take reasonable steps to monitor for transfer messages that are missing required 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. Consistent with international standards we recommend that these measures be consistent with straight-through processing where applicable.
You’ll define your risk-based approach in your anti-money laundering and counter-terrorism financing (AML/CTF) policies. This approach should consider the nature, size and complexity of your business. It must also appropriately manage and mitigate the money laundering, terrorism financing and proliferation financing risks (we refer to these as ML/TF risks) you face in providing designated services as an intermediary institution.
For example, you may determine that you’ll monitor for missing or inaccurate information by sampling transfer messages and completing other assurance activities.
What to do if a transfer message has missing information
This section refers to the Act section 66(3).
If you detect a transfer message that is missing information you must do at least one of the following:
- refuse to send the transfer message to the next business
- take any other risk-based actions described in your AML/CTF policies to reduce risk.
For example, you may determine that certain information such as the payer’s and payee’s full names are critical to manage and mitigate sanctions risk. In this case you may set up your systems to hold transfer messages that lack this information.
You may also recognise that some missing information is of a minor nature. For example, a regular payment whose purpose is clear may be missing an element of payer information on one occasion. You may decide to monitor such payments more closely for a period to understand if it’s a systemic issue that requires follow-up with the ordering institution. If you detect missing information, you may also request this information from the ordering institution or another intermediary institution and, if possible, include it in the transfer message you pass on to the next institution in the value transfer chain.
Passing on a transfer message
This section refers to the Act section 66(4).
Your role in the value transfer requires you to pass on a transfer message to the next institution in the value transfer chain.
When passing on a transfer message, the type of information you must pass on will depend on the type of transaction. However, it may include:
- the payer, payee and tracing information you received from the previous institution in the value transfer chain
- card details it received from the previous institution in the value transfer chain
- any other relevant information you have obtained by, for example, requesting missing information from the ordering institution or a previous intermediary institution in the value transfer chain.
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 5–19.
As an intermediary institution you must have AML/CTF policies that describe how you’ll:
- take reasonable steps to monitor that you’ve received all required information
- decide whether to pass on the transfer message or take other risk-based actions when you haven’t received all required information
- decide whether to request further information from another institution in the transfer chain as part of your risk-based actions.
You must also have policies, procedures, systems and controls that will support you with meeting your travel rule obligations. This includes how you’ll provide information to another institution in the value transfer chain. Your AML/CTF policies will meet this requirement if your AML/CTF policies require you to provide this information within 3 business days.
Learn more about 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 8-5.
The actions you need to take when completing a value transfer will depend on the type of transfer.
The following table provides you with guidance on what to do as an intermediary institution. Learn more about:
- travel rule obligations for ordering institutions
- travel rule obligations for beneficiary institutions.
| Type of transfer | What to do as an intermediary institution |
|---|---|
| Default position for value transfers (unless conditions below apply) |
|
| Domestic value transfers using the Bulk Electronic Clearing System (BECS), BPAY or Direct Electronic Funds Transfer (DEFT) |
|
| Multiple transfers of value from the payer where the transfers are not domestic transfers and not passed on using BECS, BPAY or DEFT |
|
| A merchant payment |
|
| Refunding a merchant payment |
|
| Withdrawal of money through an ATM |
|
| A transfer where money moves into Australia from overseas and the intermediary institution passes the transfer message through the Bulk Electronic Clearing System |
|
Related pages
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.