Prohibited and Restricted Businesses and Activities Policy
This Policy identifies businesses, activities, products, customer types and payment flows that ARMF does not support, or supports only with prior approval and additional controls. It should be read with the applicable ARMF Terms and Conditions and any product-specific terms.
Some categories are prohibited because the activity would be unlawful or inconsistent with regulatory requirements. Others are prohibited or restricted as a matter of ARMF's documented risk appetite or requirements imposed by partner financial institutions or payment networks. Inclusion in this Policy does not, by itself, mean that an otherwise lawful business is unlawful.
Purpose and scope
This Policy applies to the payment, remittance, foreign exchange, platform and related services made available by ARMF from time to time (ARMF Services). Its purpose is to support lawful use of ARMF Services and ARMF's management of money laundering, terrorism financing, proliferation financing, sanctions, fraud, scam, consumer, operational and other financial crime risks.
The Policy applies to applicants, customers and users of ARMF Services and, where relevant to the risk assessment, to their beneficial owners, controllers, authorised representatives, counterparties, merchants, sellers, underlying customers, beneficiaries and payment flows.
Where a customer provides payment, remittance, financial, marketplace or other intermediary services to its own customers, ARMF may also assess the nature of those underlying customers and payment flows to the extent reasonably required by Applicable Law and ARMF's risk-based controls.
This Policy does not create an entitlement to onboarding, continued access or any particular ARMF Service. Customer acceptance remains subject to Applicable Law, satisfactory due diligence, product eligibility, ARMF's documented risk assessment and applicable partner, correspondent and payment-network requirements.
Customer acceptance and due diligence
ARMF will not establish or continue a relationship where it cannot complete the customer due diligence and risk assessment reasonably required for the relationship or service. Depending on the customer and service, ARMF may require information and evidence concerning:
- identity, legal existence, ownership and control, and the authority of persons acting for the customer;
- the nature and purpose of the business relationship and the customer's business model;
- licences, registrations, permits and regulatory standing;
- source of funds and, where relevant or required, source of wealth;
- expected transaction activity, counterparties, underlying customers and geographic exposure;
- estimated transaction volume and frequency, including expected annual remittance value and number of transactions required for IFTI baseline risk assessment under AML/CTF Act s.45; and
- material and credible adverse information, regulatory action, criminal conduct, fraud or other financial crime risk.
Politically exposed person (PEP) status does not automatically make a person or business prohibited. ARMF will apply enhanced customer due diligence and approval requirements to foreign PEPs, and to high-risk domestic or international organisation PEPs, where required by Applicable Law. Other PEP relationships are managed on a risk-sensitive basis.
Approval of a Restricted Business or Activity may be subject to conditions such as transaction or geographic limits, additional information requirements, enhanced monitoring, product restrictions or partner approval. Approval may be reviewed if the customer's risk profile, business model or regulatory status materially changes.
Prohibited uses and activities
ARMF Services must not be used, attempted to be used, or knowingly made available for any of the following:
| Category | ARMF position |
|---|---|
| Unlawful activity | Any activity that is unlawful, or that ARMF reasonably suspects involves or facilitates unlawful conduct, including dealing with proceeds of crime. |
| Money laundering and other financial crime | Money laundering, terrorism financing, proliferation financing, bribery, corruption, tax fraud or tax evasion, sanctions evasion, structuring, transaction laundering, or conduct intended to conceal the source, destination, ownership, control or purpose of funds or assets. Where ARMF forms a suspicion, a Suspicious Matter Report (SMR) must be lodged with AUSTRAC in accordance with AML/CTF Act s.41. The tipping-off prohibition under AML/CTF Act s.123A applies. |
| Fraud and scams | Fraud, deception, impersonation, phishing, account takeover, advance-fee schemes, fraudulent fundraising, investment scams, identity theft, chargeback abuse, or knowingly receiving, transferring or dispersing proceeds of fraud or scams. |
| Sanctions or control circumvention | Any arrangement designed to evade or circumvent applicable sanctions, asset-freezing measures, export controls, transaction limits, due diligence, monitoring, reporting or other legal or regulatory controls. |
| Cybercrime and malicious activity | Ransomware, malware, credential theft, unauthorised access, denial-of-service attacks, cyber extortion, sale of stolen data or other cyber-enabled criminal activity. |
| Human exploitation and serious abuse | Human trafficking, modern slavery, forced labour, sexual exploitation, child sexual abuse material, exploitation of minors or activity facilitating such conduct. |
| False or misleading information | Providing materially false, inaccurate or misleading information to ARMF, including about identity, beneficial ownership, business activities, licences, transaction purpose, source of funds, counterparties or underlying customers. Providing false information in connection with a designated service is an offence under AML/CTF Act s.136 and may be referred to AUSTRAC or other law enforcement agencies. |
| Unlawful or infringing goods and services | Transactions involving counterfeit, pirated, stolen, illegally imported or exported goods, or goods or services that unlawfully infringe intellectual property or other proprietary rights. |
| Abuse of ARMF systems | Unauthorised access, use of another person's account without authority, transfer of account access without approval, introduction of malicious code, or other conduct that compromises the security or integrity of ARMF Services. |
Prohibited businesses, products and customer types
The following categories are outside ARMF's acceptance criteria. Some are prohibited by law; others are excluded under ARMF's risk appetite even where the underlying activity may be lawful in a particular jurisdiction.
| Category | ARMF position |
|---|---|
| Illegal or materially unlicensed businesses | Businesses that are illegal, or that conduct regulated activities without a licence, registration, permit or authorisation required in a jurisdiction in which they operate or provide the relevant product or service. |
| Prohibited sanctions exposure | Persons, entities, vessels, transactions, goods, services or activities that ARMF is prohibited from dealing with under Australian sanctions law or another sanctions regime that lawfully applies to ARMF or the relevant transaction. |
| Shell banks | Shell banks, and relationships or arrangements that would permit a shell bank to access or use ARMF Services. |
| Opaque or deceptive ownership structures | Entities or arrangements established or used to conceal true beneficial ownership or control, including sham nominee arrangements, undisclosed controlling persons, bearer arrangements where ownership cannot be satisfactorily established, or structures lacking a legitimate and verifiable business purpose. |
| Unregulated third-party financial or investment activity | Businesses that manage, pool, invest, transmit or otherwise handle third-party funds without the regulatory permissions required for that activity. |
| Binary options and fraudulent investment schemes | Binary-options businesses, Ponzi or pyramid schemes, fraudulent recruitment or investment schemes, get-rich-quick schemes, and materially deceptive investment promotions. |
| Illegal gambling | Unlicensed or unlawful gambling, wagering, lotteries, sweepstakes, games of chance, betting or similar activities. |
| Illegal drugs and controlled substances | Unlawful narcotics, controlled drugs, synthetic drugs, controlled-substance analogues, drug paraphernalia primarily intended for unlawful drug use, and products unlawfully marketed to reproduce the effects of controlled drugs. |
| Cannabis and cannabis-related businesses | Cannabis, marijuana, THC or CBD products and related businesses, including both recreational and medicinal cannabis activities. ARMF excludes all cannabis-related businesses as a documented risk-appetite decision, having regard to the cross-border and multi-jurisdictional nature of ARMF's remittance services and the divergent legal treatment of cannabis across ARMF's active corridors. This exclusion does not imply that lawfully licensed medicinal cannabis activity is unlawful. |
| Firearms, ammunition, explosives and military goods | Firearms, ammunition, explosives, military weapons or hardware, and controlled defence or strategic goods where the activity is unlawful or outside ARMF's risk appetite because of arms-control, export-control, sanctions or proliferation-financing risk. |
| Physical sexual services and adult-content businesses | Prostitution, escort or other physical sexual services, pornography or businesses primarily engaged in sexually explicit adult content. Sexual exploitation, non-consensual content and any sexual content involving minors are prohibited in all circumstances. |
| Tobacco, vaping and nicotine businesses | Tobacco, e-cigarette, vaping, e-liquid, nicotine-delivery and related businesses. This is an ARMF risk-appetite exclusion and does not imply that every such activity is unlawful. |
| Controlled dangerous goods | Explosives, radioactive materials, controlled toxic substances and other dangerous goods where the activity is unlawful or presents risk outside ARMF's documented risk appetite. |
| Bidding-fee and all-pay auctions | Bidding-fee auctions, penny auctions and similar all-pay auction models in which participants pay non-refundable fees to place incremental bids. |
| Deceptive or predatory business models | Business models materially dependent on fraud, misleading or deceptive conduct, unauthorised recurring charges, sham products or services, or practices designed to prevent customers from exercising lawful cancellation, refund or other consumer rights. |
| Counterfeit, stolen or prohibited goods | Counterfeit or pirated goods, stolen or unlawfully obtained property, illegal wildlife or environmental contraband, and goods whose possession, import, export, distribution or sale is unlawful. |
| Unlawful therapeutic goods | Counterfeit medicines, unlawfully supplied prescription medicines, therapeutic goods supplied or marketed without required approval or authorisation, and products promoted using prohibited, false or misleading therapeutic claims. |
| Tax fraud and evasion structures | Business models or ownership structures designed to facilitate tax fraud or tax evasion, conceal beneficial ownership or assets, or defeat legally required reporting or disclosure. |
| Businesses primarily designed to defeat financial-crime controls | Mixers, tumblers or other services primarily designed to obscure the source, destination or ownership of funds or virtual assets, or to defeat lawful financial-crime controls. |
Restricted businesses and activities requiring prior approval
The following categories may present heightened legal, financial crime, consumer, sanctions, fraud or operational risk. They may use ARMF Services only with ARMF's prior approval and subject to any conditions imposed following a risk-based assessment.
| Category | ARMF position |
|---|---|
| Regulated financial services and credit businesses | Banks, non-bank financial institutions, securities brokers, investment firms, fund managers, financial advisers, credit providers, mortgage brokers, debt-management, debt-collection or credit-repair businesses and similar firms. ARMF may verify AFSL, ACL, AUSTRAC or other regulatory status where applicable. |
| Payment, remittance and intermediary businesses | Remitters, payment service providers, payment facilitators, merchant aggregators, wallets, acquiring-related businesses and other entities processing or transmitting funds for third parties. Additional review may apply to their underlying customer base and payment flows. |
| Virtual asset and crypto-related businesses | Virtual asset exchanges, custodians, transfer providers, trading platforms and other virtual asset service providers. AUSTRAC enrolment and registration as a Digital Currency Exchange (DCE) or Virtual Asset Service Provider (VASP), and any other required licence or authorisation, must be verified. Travel Rule obligations apply to all VASP-to-VASP transfers from 1 July 2026. Enhanced virtual-asset transaction monitoring is required, including monitoring for transfers involving unverified self-hosted wallets. |
| Crowdfunding and crowdlending | Crowdfunding, crowdlending, peer-to-peer finance and similar platforms, subject to any required licence or authorisation, a transparent business model and satisfactory controls over investors, recipients and payment flows. |
| Licensed gambling and wagering | Lawful and appropriately licensed gambling, wagering, lotteries or gaming businesses, subject to licensing verification, geographic restrictions, ARMF risk appetite and applicable partner requirements. |
| Pharmaceuticals and therapeutic goods | Licensed pharmacies, online pharmacies, pharmaceutical businesses and sellers of regulated therapeutic goods, subject to lawful supply, required licences or approvals and product-compliance requirements. |
| Affiliate, referral and multi-level marketing | Legitimate affiliate, referral, network-marketing and multi-level-marketing businesses. Pyramid schemes, fraudulent recruitment schemes and deceptive or unfair models remain prohibited. |
| Charities, non-profits and fundraising organisations | Organisations with material cross-border, fundraising, sanctions or terrorism-financing exposure may require additional review of registration, purpose, governance, source and use of funds, geographic exposure and counterparties. Legitimate non-profit status is not, by itself, adverse. |
| Professional and trust/company service providers | Corporate service providers, accountants, tax advisers, lawyers, conveyancers, trust and company service providers and similar professionals where they manage client money, create or administer entities or trusts, or facilitate property or financial transactions. AUSTRAC enrolment or other regulatory status may be verified where applicable. |
| Real estate and property-related businesses | Real estate agents, property developers, conveyancing-related businesses and property investment structures where the service involves elevated ML/TF/PF, cross-border or third-party-funds risk. Applicable AUSTRAC or other regulatory status may be verified. |
| Precious metals, stones and other high-value goods | Dealers in precious metals and stones, jewellery, art, antiques, luxury vehicles and other high-value goods, particularly where transactions are cross-border, cash-intensive or present elevated source-of-funds or sanctions risk. |
| Import/export, freight, shipping and logistics | Cross-border trade, freight, maritime and logistics businesses, subject to sanctions, export-control, proliferation-financing and trade-based money-laundering risk assessment. |
| Marketplaces and platforms | Online marketplaces and platforms that onboard sellers or facilitate payments for third parties. ARMF may require evidence of seller-onboarding controls, prohibited-goods controls, transaction monitoring and clear responsibility for underlying users. |
| SPVs, trusts and holding companies | Special purpose vehicles, trusts and holding companies where ownership, control, purpose, source of funds and economic rationale can be satisfactorily established. Opaque or sham structures remain prohibited. |
| Cash-intensive businesses | Businesses with significant cash turnover or cash-conversion exposure where the source of funds, business activity and transaction profile require enhanced verification or monitoring. |
Sanctions and country risk
ARMF applies sanctions and geographic-risk controls to relevant customers, beneficial owners, controllers, counterparties, beneficiaries, transactions, goods, services and payment flows.
- ARMF will not process a transaction that would cause ARMF to breach Australian sanctions law, OFAC sanctions where applicable, or any other sanctions regime that lawfully applies to ARMF or the relevant transaction by reason of the currency, correspondent banking arrangement, or applicable law.
- ARMF uses the DFAT Consolidated List maintained by the Australian Sanctions Office as an important screening and due-diligence source. A name not appearing on that list does not, by itself, establish that a transaction is permitted.
- ARMF may apply additional sanctions or geographic restrictions where another sanctions regime lawfully applies to ARMF or the transaction, or where a correspondent bank, partner financial institution, payment network or service provider requires additional restrictions.
- Where a customer or relevant party is physically present in or formed in a FATF high-risk jurisdiction for which FATF calls for enhanced due diligence, ARMF will apply enhanced customer due diligence where required by Applicable Law and may impose additional restrictions or decline the relationship based on its risk assessment.
- FATF increased-monitoring status is treated as a country-risk factor. It does not, by itself, mean that a jurisdiction or every customer connected with it is prohibited.
- ARMF may restrict countries, regions, sectors, vessels, goods, services or payment corridors presenting elevated sanctions, terrorism-financing, proliferation-financing, corruption, cybercrime, fraud or other material financial-crime risk.
Licensing, registration and regulatory status
Where a business or activity requires a licence, registration, permit, professional authorisation or other regulatory approval, the customer must hold and maintain the relevant authorisation for the activities and jurisdictions concerned.
- ARMF may verify licences, registrations and regulatory standing with the relevant regulator or reliable independent sources.
- Remittance service providers and virtual asset service providers must hold AUSTRAC enrolment and registration where required for the services they provide in Australia.
- Where financial services, credit, gambling, therapeutic goods, professional services, real estate, precious-metals/stones or other activities are regulated, ARMF may require evidence of the applicable licence, enrolment, registration or approval before onboarding or continuing the relationship.
- The customer must notify ARMF within 5 business days of any suspension, expiry, cancellation, revocation or material restriction of a licence, registration or authorisation relevant to its use of ARMF Services.
Third-party, nested and payment-flow requirements
A customer must not use ARMF Services to process transactions for undisclosed third parties, or to provide nested payment, remittance, merchant or financial services, without ARMF's prior approval where such approval is required.
- Where a customer provides services to its own customers, ARMF may require information about the categories and risk profile of those underlying customers and, where reasonably necessary, specific underlying customers or transactions.
- ARMF may require a customer to maintain controls reasonably appropriate to prevent its underlying customers from using ARMF Services for Prohibited Businesses or Activities.
- ARMF may reject or restrict an underlying customer or individual payment flow even where the direct customer relationship remains approved.
- Payment flows must have a legitimate and reasonably explainable economic or legal purpose. Unexplained circular transactions, layering, back-to-back arrangements, commingling of unrelated customer funds or third-party payments inconsistent with the approved business model may be investigated, restricted or rejected.
- ARMF applies the Travel Rule to all relevant cross-border remittance instructions: originator information and beneficiary information must accompany each transfer instruction and be retained for 7 years.
- Transactions involving trade goods may be subject to additional review for trade-based money laundering, sanctions, export-control and proliferation-financing risk.
- Physical cash pay-ins or pay-outs are not permitted unless ARMF expressly offers and approves a service that allows them. Where any cash transaction is approved, any single transaction or series of related transactions totalling AUD 10,000 or more must be reported to AUSTRAC as a Threshold Transaction Report (TTR) within 10 business days under AML/CTF Act s.43. Structuring transactions to avoid the AUD 10,000 TTR threshold is a criminal offence.
Ongoing customer obligations
Customers must ensure that their actual use of ARMF Services remains consistent with the information provided to ARMF and with any approval conditions.
- Promptly notify ARMF of any material change to the business model, ownership or control, legal or regulatory status, products or services, trading names or websites, jurisdictions, customer base, counterparties, expected transaction volumes or intended use of ARMF Services.
- Do not commence a new Restricted Business or Activity, or materially change an approved payment flow, without obtaining any prior approval required by ARMF.
- Provide updated customer due diligence information and supporting documents when reasonably requested.
- Comply with Applicable Law, this Policy, the applicable ARMF Terms and Conditions, and any conditions attached to ARMF's approval of a Restricted Business or Activity.
Refusal, restriction, suspension and termination
ARMF may refuse onboarding, reject or delay a transaction, impose limits, restrict functionality, suspend Services, require additional information or terminate a relationship where reasonably necessary to:
- comply with Applicable Law, sanctions, AUSTRAC regulatory directions, court orders or law-enforcement requirements;
- complete customer due diligence, sanctions screening, fraud prevention or other financial-crime controls;
- manage a material ML/TF/PF, sanctions, fraud, scam, chargeback, operational, legal or other risk identified through ARMF's documented risk assessment;
- comply with requirements imposed by a partner bank, correspondent institution, payment network or service provider that are relevant to the Service;
- address an actual or reasonably suspected breach of this Policy or the applicable Terms and Conditions; or
- respond to a material change in the customer's business, regulatory status, risk profile or transaction activity.
Where permitted by law and reasonably practicable, ARMF will communicate a material restriction affecting the customer relationship. ARMF may be unable to provide detailed reasons where disclosure is prohibited or restricted by law, a regulatory or law-enforcement requirement, or would compromise legitimate financial-crime or security controls.
Non-exhaustive nature and changes to this Policy
The categories and examples in this Policy are not exhaustive. ARMF may classify additional customers, businesses, products, jurisdictions, activities or payment flows as Prohibited or Restricted where reasonably necessary having regard to Applicable Law, regulatory guidance, AML/CTF and sanctions risk, fraud and scam risk, payment-network rules, partner financial-institution requirements and ARMF's documented risk appetite.
ARMF may update this Policy where reasonably necessary to reflect changes in law, regulation, sanctions, financial-crime typologies, regulatory guidance, partner requirements, products or documented risk appetite. If an update materially changes the contractual rights or obligations of an existing customer, it will take effect in accordance with the applicable ARMF Terms and Conditions and Applicable Law.
Relationship with ARMF Terms and Conditions
This Policy should be read together with the applicable ARMF Terms and Conditions and any product-specific terms. Where the Terms and Conditions expressly incorporate this Policy, it forms part of the customer contract. If there is an inconsistency, the applicable Terms and Conditions prevail to the extent permitted by law. Nothing in this Policy limits any right or obligation that ARMF or a customer has under Applicable Law.
Questions and pre-approval
If you are unsure whether your business, activity, product, jurisdiction or proposed payment flow is Prohibited or Restricted, contact ARMF before using ARMF Services for that purpose.
Contact: support@ARMF.com