Anti-Money Laundering and Counter-Terrorism Financing Policy

Introduction

Get Paid in Bitcoin Pty Ltd (GPIB) is committed to complying with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act) and all applicable AUSTRAC obligations.

Our policy is designed to prevent our services from being misused for money laundering, terrorism financing, or other financial crime.

Scope

This policy applies to all employees, officers, contractors, and agents of GPIB. It covers all customer interactions, product offerings, and payment processes provided by GPIB.

Regulatory Framework

GPIB is a registered Digital Currency Exchange (DCE100576719-002) with AUSTRAC. We maintain an AML/CTF Program that complies with:

• AML/CTF Act 2006
• AML/CTF Rules 2007
• AUSTRAC guidance and reporting obligations

Oversight of AML/CTF Program

Senior management maintains ongoing oversight of the AML/CTF Program, ensuring adequate resourcing, effectiveness of controls, and adherence to all AUSTRAC and internal reporting requirements. Management receives periodic reports on key AML/CTF metrics, risks, incidents, audit findings, and remediation progress.

The Compliance Officer ensures that all AML/CTF obligations — including risk assessment, customer due diligence, transaction monitoring, reporting, recordkeeping, and staff training — are documented, implemented, and regularly reviewed.

Risk Assessment

We recognise risks associated with:

• Payroll conversion to Bitcoin
• Transfers to external wallets
• Cross-border transactions

We conduct ongoing risk assessments to ensure controls remain effective.

Customer Identification & Verification (KYC)

• Customers must provide valid identification before receiving any Bitcoin from our services.
• GPIB uses approved digital verification methods consistent with AUSTRAC rules.
• Enhanced Due Diligence (EDD) applies to higher-risk customers and transactions.

AML/CTF Program Structure

Part A — Governance, Risk Assessment, Systems & Controls

• Enterprise-wide ML/TF risk assessment
• Governance, oversight and reporting lines
• Staff training
• Independent review
• Recordkeeping procedures

Part B — Customer Due Diligence (CDD/EDD)

• Customer identification and verification
• Ongoing customer due diligence
• Enhanced due diligence for higher-risk customers, transactions, or geographies
• Ongoing monitoring of customer activity
• Sanctions screening including, but not limited to, UN, OFAC, EU, UK/OFSI, Australian (DFAT) sanction lists.
• This program is designed in accordance with the AML/CTF Act 2006, the AML/CTF Rules 2007, and AUSTRAC guidance.

Transaction Monitoring & Reporting Procedures

• GPIB monitors transactions for unusual patterns or inconsistent behaviour.
• Suspicious Matter Reports (SMRs) will be submitted to AUSTRAC promptly.
• Threshold Transaction Reports (TTRs) will be submitted for cash transactions of AUD 10,000 or more, noting that GPIB does not accept cash deposits.
• International Funds Transfer Instructions (IFTIs) will be reported where required, noting that GPIB does not accept funds from international sources as deposits.
• GPIB maintains automated and manual monitoring processes to detect unusual, inconsistent, or potentially suspicious customer activity. Alerts are reviewed promptly by trained personnel and escalated to the Compliance Officer when appropriate.
• Where reasonable grounds exist to suspect that a transaction or pattern of behaviour may relate to money laundering, terrorism financing, or other criminal conduct, the Compliance Officer will submit a Suspicious Matter Report (SMR) to AUSTRAC within statutory timeframes.
• GPIB maintains documented procedures for Threshold Transaction Reports (TTRs), International Funds Transfer Instructions (IFTIs), and any other required reporting, even where these events are unlikely due to the nature of GPIB’s services.

Record Keeping

• All KYC, transaction, and reporting records will be securely maintained for 7 years.

Staff Training

• All relevant employees receive regular AML/CTF training.
• Training covers legal obligations, red flag indicators, and reporting procedures.

Governance & Review

• GPIB has appointed a designated AML/CTF Compliance Officer who is responsible for the implementation, oversight, and ongoing maintenance of the AML/CTF Program. The Compliance Officer has appropriate authority, experience, and training to carry out these obligations effectively and reports directly to senior management and the Board where required.
• The AML/CTF Compliance Officer is responsible for oversight of this program.

Independent Review / Audit

• GPIB engages an independent, qualified reviewer at least every two years to assess the design and operational effectiveness of the AML/CTF Program. The review covers governance, CDD/EDD procedures, sanctions screening, transaction monitoring, reporting processes, training, and recordkeeping.
• Findings and recommendations from the independent audit are documented, presented to senior management, and tracked through to remediation.

Sanctions Screening Program

• GPIB maintains a Sanctions Compliance Program aligned with applicable Australian, United Nations, and international sanctions regimes. Customers, beneficial owners, and transactions are screened against relevant sanctions lists, including DFAT consolidated lists and other global sanctions databases.
• GPIB prohibits onboarding or conducting transactions for any individual or entity named on a sanctions list, located in a sanctioned jurisdiction, or otherwise subject to restrictions under applicable sanctions laws.
• Potential sanctions matches are escalated to the Compliance Officer for review, and confirmed matches result in immediate account restrictions and regulatory reporting as required.

Commitment

GPIB is committed to operating with integrity, protecting customers, and upholding the security of the Australian financial system.