Travel rule obligations for ordering institutions (Reform)
Learn what the travel rule obligation is for ordering institutions accepting the instruction to transfer value from the customer (the payer) while carrying on a business.
On this page
- Accepting the instruction from the payer
- Information you need to collect and verify
- Information required in a transfer message
- Transition to new global travel rule standards
- Travel rule policies
- Record keeping
- Completing different types of transfers
- Related pages
The travel rule overview page helps businesses to understand if they’re an ordering institution. If you’re an ordering institution this guidance will help you understand how to meet your travel rule obligations.
Accepting the instruction from the payer
The value transfer process begins with the ordering institution accepting the transfer instruction from the payer. This instruction, which may be verbal, written or implicit under a standing arrangement, such as a direct debit authority. The instruction may be provided directly to you by your customer (the payer), or indirectly via other businesses or persons.
The instruction will describe who the value is being transferred to (the payee).
The instruction from the payer is distinct from the transfer message which is used to pass on relevant information about the value transfer to other businesses in a value transfer chain.
Information you need to collect and verify
This section refers to the Act section 64(2) and the Rules sections 1–4, 8–3, 8–8.
After receiving the instruction, you must collect and verify specific information about the payer if you haven’t previously done so. As the payer is your customer, you’ll generally have collected and verified some or all of their information as part of initial customer due diligence (CDD). Any payer information you pass on in a transfer message must be verified, unless one of the exceptions in the Rules applies.
If you haven’t verified all the payer information required in a transfer message you must verify this previously unverified payer information. This must be done in accordance with your anti-money laundering and counter-terrorism financing (AML/CTF) policies related to CDD. You must verify this information before passing on the transfer message. You must also verify this information before otherwise giving effect to the transfer of value, for example, by transferring virtual assets to a self-hosted wallet.
The requirement to verify the specific elements of payer information doesn’t apply to a merchant payment or a refund of a merchant payment. If you’re a card issuer that accepts an instruction to transfer value in a merchant payment, you must collect and verify information about the payer as part of your initial CDD obligations.
Learn more about this and other exemptions on the travel rule landing page.
Collecting payer information
You must collect the payer’s full name along with information that’s one or more of the following:
- 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.
You aren’t required to re-collect information for each transfer of value if you have:
- previously collected the information as part of initial CDD, ongoing CDD or a previous transfer of value
- no reason to doubt the adequacy or truth of this information.
If you do collect information for a transfer of value and your customer provides information that is different to the know your customer (KYC) information you’ve previously collected, or there are other reasons to doubt the adequacy or truth of the information, you must:
- review their information
- update their information
- reverify their information.
Learn more about customer due diligence.
Verifying payer information
You must verify the payer information included in a transfer message before completing a value transfer.
If you’re transferring value for an existing customer, it’s likely that you’ve verified at least some of the payer’s details as part of CDD. You don’t need to reverify previously verified customer information before sending a transfer message, unless one of the triggers for reverification as part of ongoing CDD applies.
Learn more about customer due diligence.
When transferring value for new customers you must use reliable and independent data to verify information.
Learn more about initial CDD.
Collecting payee information
You must collect the payee’s name unless:
- the transfer is a merchant payment
- the transfer is refunding a merchant payment
- the instruction for the transfer is done using an ATM.
The payee’s name doesn’t need to be verified, unless the payee is also your customer and you’ve verified this information as a part of initial CDD.
Information required in a transfer message
This section refers to the Act section 64(3) and 64(4) and the Rules sections 1–4 and 8–3.
To complete a value transfer involving another business or businesses, you must send a transfer message to the next business in the value transfer chain.
If the transfer message does itself give effect to the value transfer, you must send the message before or simultaneously with giving effect to the transfer.
An example of this is where a payer is transferring virtual assets, and the distributed ledger technology (for example, blockchain) doesn’t allow for the simultaneous passing on of travel rule information. In this case the transfer message must be sent before or at the same time as giving effect to the transfer through the distributed ledger technology.
There may be cases where you collect additional information from a customer. If you do this, you may elect to include this additional information in a transfer message. However, any additional information within the scope of ‘payer information’ defined in the Rules must be verified before you pass it on with a transfer message.
If you’re both the ordering institution and the beneficiary institution for a value transfer, you must collect, and where applicable verify the payer information, and the payee’s full name. However, you don’t need to pass this information on to yourself.
Passing on or obtaining tracing information
Tracing information allows you and any other institutions in the value transfer chain to identify where the value is going or has been sent from. It can include account numbers, virtual asset wallet addresses and other associated information, or transaction reference numbers. The transfer type determines the tracing information you must provide.
Tracing information includes information related to 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 virtual asset wallet address and any destination tag or 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, you 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 virtual asset wallet address and any 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.
Sending card information
A transfer that involves a merchant payment, a refund of a merchant payment, or is an ATM withdrawal of money must include the card number in the transfer message.
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 5–17.
You must 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.
If you provide merchant payment services your policies must also enable you to provide relevant information about your business to other institutions in a value transfer chain within 3 business days of a request.
Record keeping
This section refers to the Act sections 107, 111 and 116(3).
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 you have met your travel rule obligations.
Learn more about record keeping.
Completing different types of transfers
This section refers to the Rules section 8-3.
The actions you need to take when completing a value transfer will depend on the kind of transfer.
The following table provides guidance on these actions for ordering institutions.
Learn more about:
- travel rule obligations for intermediary institutions
- travel rule obligations for beneficiary institutions.
| Type of transfer | What to do as an ordering 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 |
|
| ATM withdrawals of money |
|
| A value transfer to a self-hosted virtual asset wallet |
|
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.