Gofaizen & Sherle supports businesses applying for AUSTRAC VASP registration in Australia. We assess which requirements apply to your services, prepare the application and develop AML/CTF policies for your operations.
The Australian Transaction Reports and Analysis Centre (AUSTRAC), Australia’s AML/CTF regulator
Registration
AUSTRAC VASP registration, rather than a general crypto license
Scope
Depends on the covered services provided
Renewal
Renew every three years
AUSTRAC now uses the term virtual asset service provider (VASP), replacing digital currency exchange (DCE) provider and covering a broader range of virtual asset services.
Who Is This Service For
Launching a Virtual Asset Business in Australia For businesses that plan to exchange, transfer or hold virtual assets for customers and need to determine whether AUSTRAC registration is required.
Adding Services to an Existing Business For registered providers expanding into activities such as custody or virtual asset transfers and needing to identify additional obligations.
Serving Australian Customers From Overseas For overseas businesses that need to understand whether their services have the Australian connection that makes registration necessary.
Updating an Existing Registration For registered providers that need support with renewal or changes to ownership, key personnel or business activities.
Regulatory Routes for Your Business
The applicable route depends on your services and whether they involve financial products.
Regulatory Route
When It Applies
What It Covers
AUSTRAC VASP Registration
Your virtual asset services require Australian AML/CTF registration, without an additional AFSL requirement
Registration with AUSTRAC and the associated AML/CTF obligations
AUSTRAC VASP Registration With an Australian Financial Services Licence (AFSL)
Your business needs AUSTRAC registration and also provides financial services involving financial products, unless an exemption or representative arrangement applies
AUSTRAC registration plus the relevant financial services permissions under the AFSL
AUSTRAC registration does not replace an AFSL. Some businesses need both to provide their intended services.
Which Virtual Asset Services Are Covered
Virtual Asset Exchange Exchanging virtual assets for money or other virtual assets, including relevant arrangements.
Virtual Asset Transfer Acting as the institution sending a customer's transfer or receiving it for the recipient.
Safekeeping Holding or administering virtual assets for customers.
Issuer-Related Financial Services Participating in an issuer's virtual asset offer or sale through financial services. This does not cover every token issue.
VASP Application Support From Gofaizen & Sherle
Gofaizen & Sherle's work includes:
Assessing your business model and identifying applicable requirements.
Preparing enrollment and registration applications using your information, plus corporate documents where needed.
Preparing risk assessments and AML/CTF policies, including assessment and policy work for Travel Rule readiness.
Helping you respond to regulator questions and defining agreed implementation tasks.
You provide accurate business information and operate the controls. AUSTRAC decides whether to register the business.
What Shapes the Cost
Cost Area
Main Factors
Professional Fees
Activity breadth, ownership structure and document preparation
Implementation Costs
Operating controls, staff training and agreed operational work
Step1Gofaizen & Sherle assesses your services and their Australian connection to identify the required application.
Step2You provide business information. Gofaizen & Sherle prepares the application and policies with you.
Step3You enroll and apply through AUSTRAC Online, the regulator's application portal.
Step4AUSTRAC assesses the application and may request further information, which you must provide.
Step5AUSTRAC approves, approves with conditions or refuses registration. New applicants normally need approval before providing services. Check any conditions and put continuing controls into operation.
Information to Prepare
To assess AUSTRAC registration requirements and prepare your application, provide:
your business plan, services, customer types and target markets
ownership and control details, plus key personnel information
transaction flows, asset and wallet types, custody arrangements, turnover, countries and bank accounts
risk assessment, policies, customer checks and staff training arrangements.
How Long Can Assessment Take
The VASP application timeline separates preparation from regulatory assessment.
Preparation Duration depends on complexity and how complete your information is.
Assessment AUSTRAC may take up to 90 days to assess the application. If it requests more information, a new 90-day period starts when you provide it.
Preparation time must be added to the regulatory assessment period when planning your launch.
How Australian VASP Regulation Works
The AML/CTF Act 2006 and AML/CTF Rules 2025 govern financial-crime controls. The Australian Securities and Investments Commission (ASIC) applies the Corporations Act to financial products and services. Registration does not replace an AFSL or any required market, clearing or settlement permission. Broader licensing questions belong in your Australian licensing assessment.
Changes in 2026 and the Future Framework
Date
Status and Meaning
31 March 2026
Existing DCE registrations automatically became VASP registrations. New rules applied to virtual-asset-to-money exchange.
1 July 2026
Relevant obligations began for newly regulated services. The 29 July application concession and existing operators' service-update deadline have passed.
Governance Assign governing body, senior manager and compliance officer responsibilities. Maintain risk assessments and staff training.
Customer Controls Conduct initial and ongoing customer due diligence (CDD) and transaction monitoring according to risk.
Suspicious Matter Reporting Identify suspicions and report them within applicable deadlines.
Records and Review Keep records under the retention rules for each category and arrange independent evaluation of your program.
Registration Maintenance Renew every three years and notify relevant changes to registration information.
How the Travel Rule Affects Transfers
Transfer information duties depend on whether you send or receive assets, the counterparty and wallet type.
Under the Travel Rule, the provider sending the assets is called the ordering institution, and the one receiving them is the beneficiary institution. Apply the information and policy requirements for your role.
Self-hosted wallets are controlled by users rather than service providers. Transfers to them are exempt from passing information to another organization, while customer checks and risk controls remain
Special reports involving unverified self-hosted wallets start on 31 March 2029 for relevant services begun earlier. Other duties, including suspicious matter reporting, continue.
What Creates Regulatory Risk
Providing services without required registration creates regulatory risk.
AUSTRAC can suspend or cancel registration. Address compliance failures and avoid describing registration as a general crypto license or permission for every market.
Preparing for Banking
AUSTRAC registration does not provide a bank account.
Gofaizen & Sherle assists with Australian crypto business banking by matching providers and preparing documents. Banks and electronic money institutions assess transaction flows, source of funds and compliance documents. The bank or payment institution reviews your application and decides whether to open the account.
Combined Permissions and Company Acquisition
Situation
Practical Next Step
New AUSTRAC VASP registration
Prepare the application and controls for your intended services.
Current AFSL overlap
Assess ASIC permissions alongside registration. One does not replace the other
DAF platform planning from 8 April 2027
Check platform coverage and consultation developments while meeting current duties.
Ready-made company acquisition
Check entity identity, liabilities, service scope, suitability, registration conditions and ownership or personnel notifications. Do not assume automatic transfer.
Can an overseas business need Australian registration?
Yes, if its covered services have the required geographical connection to Australia. Overseas ownership alone does not decide applicability.
Does software alone make us a VASP?
The services you actually perform determine applicability. A software label neither establishes VASP status nor creates a blanket exemption.
When does the seven-year CDD retention period start?
Keep CDD records for seven years after the customer relationship ends or the occasional transaction occurs. The period does not start at onboarding; other record categories have different starting points.
Does submitting an application let us start trading?
Normally, approval is required before providing services. The July 2026 transitional application concession is no longer open.
What if AUSTRAC requests more information?
Providing the requested information starts a new 90-day assessment period, rather than merely resuming the original period.
How often is independent AML/CTF evaluation required?
At least every three years, with frequency reflecting the business’s nature, size and complexity. First evaluations follow staggered transitional deadlines, rather than a universal three-year grace period.
What happens if renewal is filed late?
Apply within the 90 days before expiry. Timely renewal preserves registration pending a decision; otherwise it lapses and you need a new application.
Are all self-hosted wallet duties postponed until 2029?
No. The narrow special-reporting deferral and information-transfer exception leave customer checks, risk controls and suspicious matter reporting in place.
Can one business need both registration and an AFSL?
Yes, where the asset’s rights and arrangements constitute financial products and the business provides relevant financial services.
When must ownership or key personnel changes be reported?
Registered VASPs must notify AUSTRAC within 14 days of relevant ownership, key personnel or other registration-circumstance changes. Notification does not automatically transfer registration.
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