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Australia's new IVTS reporting framework replaces IFTI reports from 31 March 2025, fundamentally changing how remittance operators report international transfers to AUSTRAC. The International Value Transfer Service (IVTS) framework shifts reporting obligations, introduces new data fields, and requires structural changes to your compliance systems.
The transition from International Funds Transfer Instructions (IFTIs) to IVTS reporting represents the most significant change to cross-border transaction reporting since 2006. For the 5,100+ registered remittance providers in Australia, this means updating systems, retraining staff, and potentially restructuring business relationships by 30 June 2025 to avoid penalties.
Key Takeaways
• IVTS reporting obligation falls on the entity providing the service to the customer, not necessarily the entity moving the funds • New data fields include beneficial ownership information, purpose codes, and enhanced counterparty details • Reporting timeframe remains 10 business days but calculation method changes • Non-compliance penalties increase to AUD 5.5 million for bodies corporate under the 2026 reforms • Legacy IFTI reports must still be accessible for 7 years from transaction date
What Is IVTS Reporting and Why It Matters
The International Value Transfer Service (IVTS) framework replaces the IFTI reporting regime as part of the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024. Under section 45B of the amended AML/CTF Act, any entity providing international value transfer services must submit IVTS reports to AUSTRAC.
The critical difference lies in who reports. Under the old IFTI regime, the entity physically moving funds submitted reports. Under IVTS, the entity with the customer relationship bears the reporting obligation. This shift particularly impacts agent networks and white-label arrangements.
For example, if RemitCo uses BigBank's rails to send AUD 5,000 from Sydney to Mumbai, RemitCo now submits the IVTS report — not BigBank. This change aligns Australia with FATF Recommendation 16 on wire transfers and the global move toward capturing beneficial ownership data.
IVTS vs IFTI: Core Structural Differences
The structural changes between IFTI and IVTS reporting extend beyond who reports. Here's what changes:
| Aspect | IFTI (Old) | IVTS (New) |
|---|---|---|
| Reporting Entity | Institution moving funds | Service provider to customer |
| Reporting Trigger | Fund movement | Service provision |
| Data Fields | 23 standard fields | 37 fields including UBO |
| Batch Reporting | E2 and E3 only | All IVTS types |
| Threshold | All amounts | All amounts |
| Format | XML via AUSTRAC Online | XML or REST API |
| Retention | 7 years | 7 years |
Service-Based vs Movement-Based Reporting
IFTI reporting followed the money — whoever initiated the SWIFT message or bank transfer submitted the report. IVTS reporting follows the service relationship. This means:
- Agent networks: The principal (not the agent) reports
- White-label providers: The brand owner reports
- Correspondent banking: The originating institution reports
- Nested services: Each service provider reports their leg
This shift captures the full remittance ecosystem, not just the banking layer.
Enhanced Data Requirements
IVTS reports require 37 data fields compared to IFTI's 23. New mandatory fields include:
- Beneficial owner details for amounts over AUD 1,000
- Purpose of remittance codes aligned with ISO 20022
- Relationship between sender and receiver
- Source of funds with documentary evidence reference
- Digital wallet identifiers for mobile money transfers
- Sanctions screening results and match percentages
Optional fields that strengthen your compliance position include occupation codes, tax identification numbers, and enhanced address verification flags.
Who Must Submit IVTS Reports
Under section 45B, any "reporting entity" providing international value transfer services must submit IVTS reports. This includes:
Primary Reporting Entities
- Remittance dealers (AUSTRAC-registered MTOs)
- Banks offering international transfers
- Non-bank financial institutions with AFSL authorisation
- Digital currency exchange providers facilitating cross-border transfers
Clarifications on Agent Networks
The Remittance Network Provider (RNP) structure creates clear reporting lines:
- RNP principals report all transactions conducted through their network
- Affiliates do not report separately unless providing additional services
- Independent agents must register separately and report their own transactions
For example, if MoneyGram processes a transfer through an Australian newsagent, MoneyGram Australia (the RNP) submits the IVTS report — not the newsagent.
White-Label and Partnership Arrangements
White-label arrangements require careful analysis:
- Brand owner reports if they control the customer relationship
- Platform provider reports if they manage KYC and compliance
- Both parties may need to report if providing distinct services
AUSTRAC's Regulatory Guide 8.2 provides a decision tree for determining reporting obligations in complex arrangements.
New Data Fields and Requirements
The expanded IVTS data model aligns with ISO 20022 messaging standards and captures the full context of international transfers. Here's what you must now collect:
Mandatory Customer Information
- Full legal name (no initials)
- Date of birth (individuals) or registration date (entities)
- Residential address (not PO boxes)
- Nationality and country of birth (new)
- Tax residency status (new)
- Occupation or business type
- Government-issued ID details with document verification status
Transaction-Specific Data
- Unique transaction reference (UTR)
- Amount in sending currency
- Amount in receiving currency
- All fees disclosed separately (new requirement)
- Exchange rate applied with 4 decimal places
- Purpose code from AUSTRAC's approved list
- Relationship code between parties
Beneficial Ownership (Transactions Over AUD 1,000)
- Ultimate beneficial owner details if different from sender
- Ownership percentage for entity transactions
- Control structure for trust or company transfers
- Source documentation reference
Enhanced Compliance Fields
- Sanctions screening timestamp and system used
- PEP status with classification level
- Risk rating applied to transaction
- Any compliance overrides with justification
System Changes Required for IVTS Compliance
Transitioning from IFTI to IVTS reporting requires technical and operational changes:
Technical Infrastructure
API Integration: AUSTRAC's REST API supports IVTS reporting from 1 April 2025. Key endpoints:
/ivts/submitfor individual reports/ivts/batchfor bulk submissions/ivts/status/{id}for confirmation
The legacy AUSTRAC Online portal will support IVTS submissions until 31 December 2025, after which API submission becomes mandatory.
Data Mapping: Your systems must map existing IFTI fields to new IVTS fields:
IFTI Field → IVTS Field
Customer name → customer.fullLegalName
Address → customer.residentialAddress (structured)
Amount → transaction.sendAmount + transaction.sendCurrency
Beneficiary → receiver.details (expanded)
Operational Requirements
Staff Training: Front-line staff must understand:
- New data collection requirements
- When to escalate for beneficial ownership
- Purpose code selection
- Relationship verification
Quality Assurance: Implement checks for:
- Data completeness (all 37 fields)
- Format validation (ISO standards)
- Logical consistency (amounts, dates)
- Sanctions screening evidence
Record Keeping: Maintain both:
- Original IFTI records for 7 years
- New IVTS records from transition date
- Mapping documentation for audit trails
Timeline and Deadlines
The transition to IVTS reporting follows this mandatory timeline:
| Date | Milestone | Action Required |
|---|---|---|
| 31 March 2025 | IVTS framework commences | Begin parallel reporting |
| 1 April 2025 | REST API available | Test system integration |
| 30 June 2025 | Grace period ends | Full IVTS compliance required |
| 31 December 2025 | Portal submission ends | API-only reporting |
| 31 March 2026 | First annual review | AUSTRAC compliance assessment |
Parallel Reporting Period (31 March - 30 June 2025)
During the transition quarter:
- Continue IFTI reporting for transactions initiated before 31 March
- Submit IVTS reports for new transactions from 31 March
- Double reporting not required — each transaction reports once
- Test systems using AUSTRAC's sandbox environment
Post-Transition Requirements
From 1 July 2025:
- All international transfers must use IVTS reporting
- Non-compliance attracts penalties under section 235
- AUSTRAC begins compliance monitoring
- Quality metrics affect risk ratings
Common Pitfalls to Avoid
Misidentifying the Reporting Entity
The most common error involves agent networks. Remember:
- Service provider reports, not fund mover
- RNP principals report for their entire network
- Sub-agents cannot delegate reporting up
Example: GlobalRemit uses ANZ's banking rails. GlobalRemit must submit the IVTS report because they provide the service to the customer, even though ANZ moves the funds.
Incomplete Beneficial Ownership Data
For business remittances over AUD 1,000:
- Identify all persons owning 25% or more
- Trace through corporate structures
- Document the verification method
- Update annually or on change
Missing UBO data represents 32% of AUSTRAC enforcement actions under the pilot program.
Incorrect Purpose Codes
AUSTRAC's purpose code list includes 47 categories. Common errors:
- Using "Other" when specific codes exist
- Mixing personal and business codes
- Not matching code to documentation
Purpose codes directly impact:
- Transaction monitoring rules
- Risk scoring algorithms
- Regulatory reporting to RBA
Technical Integration Failures
Avoid these system errors:
- Truncating data fields (names, addresses)
- Rounding exchange rates (use 4 decimals)
- Timezone confusion (use AEST/AEDT)
- Batch size limits (max 1,000 per submission)
Best Practices for IVTS Implementation
Data Quality Management
Implement a three-tier quality framework:
- Collection: Validate at point of entry
- Processing: Apply business rules
- Submission: Pre-submission audit
Quality metrics to track:
- First-time acceptance rate (target >95%)
- Data completeness score
- Rejection reasons by category
- Time to correction
Documentation and Audit Trails
Maintain clear records of:
- Decision logs for reporting entity determination
- Data source for each IVTS field
- Override justifications for exceptions
- System change documentation
AUSTRAC compliance reviews examine your methodology, not just outcomes.
Vendor and Partner Management
For organisations using third-party platforms:
- Contract updates reflecting IVTS obligations
- SLAs for data provision timing
- Liability allocation for reporting failures
- Access rights to AUSTRAC systems
Continuous Monitoring
Establish KPIs for IVTS compliance:
- Submission timing (within 10 business days)
- Rejection rates by type
- Data quality scores
- System availability
Review metrics monthly and adjust processes based on trends.
Impact on Different Business Models
The IVTS framework affects remittance business models differently:
Traditional Agent Networks
RNP principals face the highest burden:
- Consolidate reporting across all affiliates
- Standardise data collection procedures
- Invest in centralised compliance systems
- Renegotiate affiliate agreements
Estimated compliance cost: AUD 50,000-200,000 for system upgrades
Digital-First Providers
Online remittance providers benefit from:
- Existing digital data capture
- Automated API integration
- Real-time validation capabilities
- Lower manual processing costs
Key challenge: Retrofitting systems for new fields
Bank-Partnered MTOs
Organisations using banking rails must:
- Clarify reporting responsibilities
- Establish data-sharing protocols
- Separate service from movement
- Maintain independent records
Risk area: Conflicting compliance interpretations
Cryptocurrency-Enabled Services
Digital asset providers face unique requirements:
- Wallet address verification
- Blockchain transaction mapping
- Virtual asset service provider (VASP) data
- Travel rule compliance
Additional fields: Digital asset type, protocol used, smart contract address
Preparing Your Compliance Team
Training Priorities
- Regulatory Framework: Understanding sections 45B-45E of the amended Act
- Data Requirements: All 37 IVTS fields and when they apply
- System Changes: New interfaces and validation rules
- Quality Standards: AUSTRAC's expectations for data accuracy
Resource Planning
Budget for:
- Additional staff hours during transition (20-30% increase)
- External compliance review (AUD 10,000-25,000)
- System integration (AUD 30,000-100,000)
- Ongoing training (AUD 5,000 annually)
Compliance Documentation Updates
Revise these documents by 30 June 2025:
- AML/CTF Program Part A (reporting procedures)
- Standard operating procedures
- Staff training materials
- Board reporting templates
- Technology vendor contracts
Frequently Asked Questions
What happens to our existing IFTI reports after 31 March 2025?
Existing IFTI reports remain valid and must be retained for 7 years from the transaction date. You cannot retroactively convert IFTIs to IVTS format. AUSTRAC will maintain access to historical IFTI data, and you may need to provide these records during compliance reviews. Ensure your record-keeping system clearly distinguishes between IFTI and IVTS reports.
Can we continue using AUSTRAC Online for IVTS reporting?
Yes, but only until 31 December 2025. AUSTRAC Online will accept IVTS reports during the transition period, giving smaller operators time to implement API integration. However, the portal will not support all new IVTS fields, potentially limiting your compliance capability. Plan for API migration by October 2025 to allow testing time.
How do we determine the reporting entity in white-label partnerships?
The entity maintaining the direct customer relationship typically bears the IVTS reporting obligation. This means: if customers know your brand and you control the service terms, you report. If you're purely providing technology or rails, your partner reports. Document this determination in your service agreements and review with legal counsel to ensure clarity.
What are the penalties for late or incorrect IVTS reporting?
Under section 235 of the amended AML/CTF Act, penalties for non-compliance with IVTS reporting include: AUD 5.5 million for bodies corporate or AUD 1.1 million for individuals. Late submission (beyond 10 business days) attracts penalties starting at AUD 22,000 per report. Systemic failures or wilful non-compliance may result in licence suspension or criminal prosecution.
Moving Forward with IVTS Compliance
The shift from IFTI to IVTS reporting represents both a compliance challenge and an opportunity to modernise your remittance operations. Organisations that embrace the enhanced data requirements will find themselves better positioned for future regulatory changes and customer expectations.
Start by auditing your current IFTI processes, identifying gaps in data collection, and establishing clear reporting responsibilities across your business network. The 30 June 2025 deadline approaches quickly, but organisations taking action now can achieve compliance while strengthening their overall AML/CTF framework.
For detailed technical specifications and API documentation, visit AUSTRAC's REST API portal. To assess your current compliance readiness, try our IVTS Readiness Checklist.
This information is general in nature and does not constitute legal advice. Consult AUSTRAC or a qualified legal professional for advice specific to your situation.
