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Kestrel Assurance
Front-line CDDCertificate of completion

Iranian MSB Responsibilities for Australian Money Service Businesses

Iran-related obligations for Australian money service businesses. Registration and the AML/CTF framework, Iran-related ML, TF, PF and sanctions risk, onboarding and verification, risk rating and screening, pre-transaction controls, ongoing monitoring, suspicious matter reporting and tipping off, and regulatory reporting and recordkeeping.

8 modules · 82 lessons · 478 min

$249

12 months’ access from purchase · ex GST

  • On-demand, watch on any device
  • Branded completion certificate
  • Knowledge assessment

General information only, current as at 1 September 2026. Not legal, financial or regulatory advice. Laws and AUSTRAC guidance change. Use at your own discretion. See our content disclaimer.

About this course

Australian money service businesses handling Iran-related business carry obligations that sit on top of the ordinary AML/CTF regime: autonomous and United Nations sanctions, proliferation financing risk, and the practical problem of processing remittances where a counterparty, a bank or a routing path may be sanctioned. This course covers those obligations end to end. Eight modules. The first two establish the framework and the risk: registration as a remittance provider, the four pieces of the Australian AML/CTF framework, what a contravention carries, and why Iran-related business attracts specific ML, TF, proliferation financing and sanctions risk. The next three cover the customer: onboarding, identification and verification; customer risk rating, screening and enhanced due diligence; and the pre-transaction control lifecycle. The last three cover what happens afterwards: ongoing customer due diligence, transaction monitoring and investigation; suspicious matter reporting and tipping off; and regulatory reporting, recordkeeping and governance, including IFTI and threshold reporting, the travel rule, seven-year recordkeeping, training and breach management. The course assumes working familiarity with day-to-day remittance operations rather than legal training, and concentrates on the decisions an operator, an analyst or a compliance officer actually has to make.

Curriculum

Australian AML/CTF Framework and MSB Responsibilities

  • Australian Money Service Businesses and the AML/CTF FrameworkPreview7 min
  • The Australian AML/CTF Framework6 min
  • Currency of This Course5 min
  • Money Laundering and Terrorism Financing7 min
  • Proliferation Financing and Iran-Related Risk6 min
  • Core Responsibilities and Who Does What8 min
  • Frontline Responsibilities and Recognising the Categories6 min
  • Case Study Assessment and Key Takeaways4 min

Iran-Related ML, TF, PF and Sanctions Risks

  • Why Iran Is Considered Higher Risk5 min
  • What the FATF Call on Iran Actually Is8 min
  • Legitimate Activity and the Main Risk Categories5 min
  • Bank Transfer and Third-Party Funding Risk5 min
  • Cash, Structuring and Multiple Senders7 min
  • Multiple Beneficiaries and Money-Laundering Risk6 min
  • Terrorism Financing, Proliferation Financing and Sanctions Risk6 min
  • Incoming Funds From Iran and Risk Indicators6 min
  • Non-Individual Customers and Proportionate Response6 min
  • Unresolved Concerns and the Practical Case Study6 min
  • Analyst Tips and Key Takeaways5 min

Customer Onboarding, Identification and Verification

  • Initial Customer Due Diligence7 min
  • The Onboarding Lifecycle, Collection and Verification6 min
  • Establishing and Verifying Customer Identity6 min
  • Document Review, Name Variants and Representatives6 min
  • Translator or Representative, Customer or Third-Party Funds4 min
  • Understanding Nature and Purpose, and Source of Funds5 min
  • Initial Customer Risk Assessment and Non-Individual Customers6 min
  • Discrepancy Management and When Onboarding Must Be Paused5 min
  • Practical Case Study, Leila’s Onboarding5 min
  • Analyst Tips, Common Mistakes and Key Takeaways5 min

Customer Risk Rating, Screening and Enhanced Customer Due Diligence

  • What Customer Risk Ratings Are For6 min
  • Customer Risk Versus Transaction Risk, and the Relevant Risk Factors7 min
  • Name Screening, Who and When to Screen, and Introducing PEPs10 min
  • Relatives, Close Associates, and Iran-Related PEP Challenges5 min
  • Australian Targeted Financial Sanctions5 min
  • Indirect Sanctions Exposure and Investigating a Screening Alert6 min
  • Assessing Adverse Media, and What Enhanced Customer Due Diligence Actually Is5 min
  • ECDD Triggers and ECDD Measures for an Iran-Related Remittance Provider6 min
  • Additional Controls, and Source of Funds Versus Source of Wealth6 min
  • Source-of-Funds Examples, Senior Approval and ECDD Outcomes5 min
  • Practical Case Study, the Medical-Expenses File5 min
  • Analyst Tips, Common Mistakes and Key Takeaways6 min

Transaction Processing and Pre-Transaction Controls

  • The Pre-Transaction Control Lifecycle5 min
  • Authenticating the Customer and Confirming the Transaction Record5 min
  • Beneficiary Information, Transaction Purpose and the Beneficiary Relationship6 min
  • How the Beneficiary Receives Value, and Australian Bank-Transfer Controls5 min
  • Joint-Account, Company and Third-Party Funding, and Cash Transaction Controls6 min
  • Cash Thresholds, Structuring and the Source-of-Funds Test6 min
  • Pre-Transaction Screening and Payment-Channel Checks7 min
  • The Pre-Transaction Decision and Refund Risk6 min
  • Regulatory Information at Transaction Stage, and the Sara Case Study5 min
  • Analyst Tips, Common Mistakes and Key Takeaways5 min

Ongoing CDD, Transaction Monitoring and Investigation

  • What Ongoing Customer Due Diligence Is, and Why It Never Stops6 min
  • What the MSB Must Monitor For, and How6 min
  • A Worked Example, Risk-Based Monitoring and the First Three Common Scenarios5 min
  • Shared Beneficiaries, Third-Party and Cash Risk, and the First Step of an Investigation6 min
  • Investigation Steps Two to Four, Reviewing the Customer, the History and the Consistency6 min
  • Reaching a Defensible Conclusion and Expanding the Review6 min
  • Assessing Customer Explanations and Updating KYC and Risk6 min
  • Alert Outcomes, Documentation Standards and Monitoring Completion6 min
  • Avoiding Investigation Bias, a Practical Case Study6 min
  • Closing the Case, Analyst Practice and Module Key Takeaways6 min

Suspicious Matters, SMR Reporting and Tipping-Off

  • Suspicious Matter Reports: Purpose and Scope7 min
  • Suspicion Without Proof: Reasonable Grounds and the First SMR Triggers6 min
  • SMR Triggers: False Information, Third-Party Funding, Unregistered Activity, Scams, Sanctions and Terrorism Financing6 min
  • Proliferation-Financing Indicators, Attempted Transactions and Internal Escalation6 min
  • Authorised Decision-Makers and the SMR Reporting Clock5 min
  • When One SMR Is Not Enough: ECDD, New Suspicions and TTRs6 min
  • Sanctions Reporting, Continuing the Service and the Start of Tipping Off5 min
  • Why Tipping Off Is Dangerous, and What Employees Should Never Say6 min
  • Conducting CDD Without Tipping Off, and Preparing a Useful SMR6 min
  • From Weak to Strong: A Stronger Narrative, Facts and Documented Non-Reports6 min
  • When an Explanation Is Reasonable, and When It Isn’t: Maryam’s Case6 min
  • Analyst Tips, Common Mistakes and Key Takeaways for SMR Reporting6 min

Regulatory Reporting, Recordkeeping and Governance

  • Module Purpose, Separate Reporting Obligations and the Shift from IFTI to IVTS6 min
  • From IFTI-DRA to IVTS, and What Counts as an International Value Transfer6 min
  • Offsetting, the Parties in a Transfer, and Reporting It Accurately7 min
  • Travel-Rule Responsibilities and Incoming Transfers from Iran5 min
  • Threshold Transaction Reports, Structuring, and Ongoing Compliance Obligations7 min
  • AML/CTF Recordkeeping and the Records a Provider Must Retain6 min
  • Settlement-Partner Oversight and Governance Responsibilities6 min
  • Breach Management, Program Review and Independent Evaluation5 min
  • Case Study in Control Failure, and Module 8 Key Takeaways6 min
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Iranian MSB Responsibilities for Australian Money Service Businesses · Kestrel Assurance