1. Our commitment
Southledger is a reporting entity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and is registered with AUSTRAC as a virtual asset service provider (VASP). Our registration can be checked on AUSTRAC's public register under our legal entity name. We run an AML/CTF program approved by our board and overseen by a designated AML/CTF Compliance Officer.
2. Legal framework
Our program is designed to meet:
- The AML/CTF Act 2006 (Cth) and the AML/CTF Rules issued by AUSTRAC
- Australian sanctions laws, including the Autonomous Sanctions Act 2011 (Cth) and the Charter of the United Nations Act 1945 (Cth)
- The Financial Action Task Force (FATF) recommendations for virtual asset service providers, including the Travel Rule
3. Customer due diligence
Standard checks
Before you can trade, we verify your identity as set out in our KYC Policy. We also collect information about the purpose of your account and, where needed, the source of your funds.
Enhanced checks
We apply extra scrutiny, which may include source-of-wealth evidence and senior approval, where risk is higher, for example:
- Politically exposed persons (PEPs), their family members and close associates
- Customers linked to higher-risk countries
- Large, frequent or unusual transactions
- Complex ownership structures for business accounts
4. Ongoing monitoring
We monitor accounts and transactions continuously using automated rules, blockchain analytics and machine-learning tools, backed by trained analysts. This includes:
- Screening wallet addresses for links to scams, darknet markets, mixers and sanctioned parties
- Spotting unusual patterns, such as rapid movement of funds or structuring to avoid thresholds
- Reviewing customer information periodically and when circumstances change
5. Reporting to AUSTRAC
Where required, we report to AUSTRAC, including:
- Suspicious matter reports when we suspect a transaction may relate to crime
- Threshold transaction reports for physical cash transactions of A$10,000 or more
- International funds transfer instructions where applicable
The AML/CTF Act makes it an offence (“tipping off”) to disclose information that could reasonably be expected to prejudice an investigation, including that a suspicious matter report has been made. We therefore will not confirm or deny whether any report exists.
6. Sanctions screening
We screen customers and transactions against the Australian Consolidated Sanctions List maintained by DFAT, as well as UN, US (OFAC), UK and EU lists. We will not deal with sanctioned persons or with prohibited jurisdictions, and we will freeze assets where the law requires.
7. Travel Rule
For every digital asset transfer, whatever its value, we collect and pass on the sender and recipient information required by the AML/CTF Rules and FATF standards. For transfers to or from a self-hosted (personal) wallet, we ask for the name of the other party and may ask you to show that you control the wallet. We may hold or return transfers that arrive without the required information.
8. Record keeping
We keep identification records, transaction records and AML/CTF program records for at least 7 years, as required by law.
9. Training and review
All staff receive AML/CTF training when they join and at least once a year. Our program is reviewed independently on a regular basis and updated as risks and laws change.
10. What we may do
To meet our obligations, we may request more information, delay or refuse transactions, freeze assets, or close accounts. In some cases we cannot tell you the reason.
11. Contact
AML/CTF Compliance Officer: compliance@southledger.com