AML/CTF Policy

Effective date: 16 March 2026 · Last updated: 16 March 2026

Sabeam Pty Ltd (“Sabeam”) is committed to preventing its services from being used for money laundering, terrorism financing, or other financial crimes. This policy summary outlines the measures we take to comply with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (“AML/CTF Act”) and associated rules.

1. Our Commitment

Sabeam maintains an AML/CTF program that is designed to:

  • Identify, assess, and manage money laundering and terrorism financing risks
  • Implement appropriate customer identification and verification procedures
  • Monitor transactions for suspicious activity
  • Report to AUSTRAC as required by law
  • Maintain records in accordance with statutory requirements
  • Provide ongoing training to our personnel

2. Customer Identification

Before you can use certain features of the Sabeam platform, we are required to verify your identity. This process is known as Customer Due Diligence (CDD) and may include:

  • Collecting your full name, date of birth, and residential address
  • Verifying your identity against government-issued documents
  • Verifying your identity electronically through the Australian Document Verification Service (DVS)
  • Collecting and verifying business registration details (for business accounts)

In certain circumstances, we may be required to conduct Enhanced Due Diligence (EDD), which involves additional verification steps. We will communicate any additional requirements to you directly.

3. Ongoing Monitoring

We monitor transactions processed through the platform on an ongoing basis to identify activity that may be unusual or inconsistent with expected patterns. This monitoring is conducted using a combination of automated systems and manual review.

4. Reporting Obligations

Sabeam is required to report certain matters to AUSTRAC, including suspicious matters and threshold transactions. We are prohibited by law from disclosing to any person (including you) whether a report has been made or is being considered.

5. Record Keeping

We retain customer identification records and transaction records for a minimum of 7 years in accordance with the AML/CTF Act. Records are stored securely and access is restricted to authorised personnel.

6. Your Obligations

As a user of the Sabeam platform, you agree to:

  • Provide accurate and complete identification information
  • Promptly update your information if it changes
  • Not use the platform for any illegal purpose, including money laundering or terrorism financing
  • Cooperate with any reasonable requests for additional information or documentation
  • Not structure transactions to avoid reporting thresholds

7. Consequences of Non-Compliance

If we are unable to verify your identity or if we have reasonable grounds to suspect that your account or transactions are associated with illegal activity, we may:

  • Suspend or restrict access to your account
  • Delay or withhold transactions
  • Terminate your access to the platform
  • Report the matter to the relevant authorities

8. Sanctions Screening

Sabeam screens customers against applicable sanctions lists, including those maintained by the Australian Department of Foreign Affairs and Trade (DFAT) and relevant international bodies. We will not provide services to sanctioned individuals or entities.

9. Politically Exposed Persons

We apply enhanced scrutiny to accounts held by or associated with politically exposed persons (PEPs) and their close associates, in accordance with our risk-based approach.

10. Contact

If you have questions about our AML/CTF obligations or the identification process, contact us at compliance@sabeam.com.au.

For information about AUSTRAC and the AML/CTF Act, visit www.austrac.gov.au.