From 3 April 2018 DCE businesses are required to meet AML/CTF obligations, including:
- adopting and maintaining an AML/CTF program to identify, mitigate and manage money laundering and terrorism financing risks
- identifying and verifying the identities of their customers
- reporting to AUSTRAC suspicious matters, and transactions involving physical currency of $10,000 or more
- keeping certain records for seven years.
A 'policy principles' period of six months will be in place from 3 April 2018. During that period, the AUSTRAC CEO can only take enforcement action if a DCE business fails to take 'reasonable steps' to comply.
Transitional registration arrangements will be in place for existing businesses to allow them to continue providing services while their registration application is being considered. Existing businesses providing DCE services will need to register by 14 May 2018.
There will be criminal offence and civil penalty consequences if you provide digital currency exchange services without being registered.