AML/CTF Policy

Legal

AML/CTF Policy

1. Purpose

This Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) Policy explains our approach. It outlines how Bradford Coins & Stamps identifies and manages AML/CTF risks. It also explains how we manage those risks. It outlines our steps. It also explains our controls. These help us meet our duties under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth). It also covers relevant AUSTRAC rules and guidance. 

The purpose of this policy is to help prevent our business from being used for:

  • money laundering
  • terrorism financing
  • other financial crime

2. Scope

This policy applies to all customers and covers:

  • customer identification and verification (Know Your Customer – KYC)
  • transaction monitoring
  • reporting suspicious matters and threshold transactions
  • record keeping

3. Customer Identification and Verification (KYC)

3.1 When we verify identity
We verify the identity of customers involved in:

  • transactions of AUD $5,000 or more
  • cash transactions of AUD $10,000 or more (Threshold Transaction Reports)
  • any activity we consider suspicious, no matter the value

3.2 How we verify identity
We may collect identification by:

  • checking government-issued ID in person
  • receiving a scanned copy of ID by email or secure upload
  • using an approved third-party digital ID verification service

3.3 Companies, trusts, and SMSFs
If the customer is a company, trust, or SMSF, we may request extra documents, such as:

  • an ASIC company extract or ABN registration
  • trust deeds and related records
  • identification for directors, trustees, and beneficiaries (as applicable)

3.4 Order processing
We will not finalise, dispatch, or deliver any order until we verify the customer’s identity. This is required under AUSTRAC rules.

4. Transaction Monitoring and Reporting

4.1 What we monitor
We monitor transactions to identify:

  • unusual patterns or behaviour
  • transaction “structuring” to avoid reporting thresholds
  • repeated purchases just under reporting limits

4.2 What we report to AUSTRAC
We must report the following to AUSTRAC:

  • Threshold Transaction Reports (TTR): cash transactions of AUD $10,000 or more
  • Suspicious Matter Reports (SMR): any transaction that we suspect may involve money laundering, terrorism financing, or other unlawful activity

We submit reports securely through AUSTRAC’s online portal within the required timeframes.

5. Record Keeping

5.1 What we keep
We keep complete and accurate records of:

  • KYC documents and customer identification
  • transaction details and payment methods
  • any reports submitted to AUSTRAC

5.2 How long we keep records and how we protect them
We store records in encrypted digital systems for at least seven (7) years, as required by law. Only authorised staff can access these records.

6. Policy Review

We review this policy each year. We also review it when laws change. We also review it if AUSTRAC guidance changes. We also review it if our business operations change.

7. Contact

For questions about this AML/CTF Policy, contact:

Bradford Coins & Stamps
Phone: (07) 4051 3784
Email: bradco@bigpond.net.au
Website: www.bradfordcoins.com.au
Address: 165 Bunda St, Parramatta Park QLD 4870

!