SBX Money Pty Ltd.
ACN : 145 767 666
Head Office :48 Railway Pde.Lakemba, NSW-2195, Australia.

Anti-Money Laundering & Counter Terrorist Financing Policies and Procedures

As SBX Money Pty Ltd is involved in money remittance business one of its responsibilities is to report to AUSTRAC

AUSTRAC is Australia's anti-money laundering and counter-terrorism financing regulator and specialist financial intelligence unit. AUSTRAC works collaboratively with Australian industries and businesses in their compliance with anti-money laundering and counter-terrorism financing legislation. As Australia's financial intelligence unit, AUSTRAC contributes to investigative and law enforcement work to combat financial crime and prosecute criminals in Australia and overseas.

As the representative will also be involved in money transfer service, hence providing a designated service, the representative will be required to register with AUSTRAC by visiting their website www.austrac.gov.au/register or by calling 1800 021037. The representative shall comply with all AUSTRAC requirements including submitting an AUSTRAC compliance report.

At SBX Money Pty Ltd, we understand that money transfer service is not the representative's core business activity therefore to make things easier for our representatives we have set some procedures that the Representative shall follow to make reporting easier and counter threats associated with money laundering and other illegal activities.

Important terms

What is Money Laundering ?
Point 1.
Money laundering is the process by which money earned from illegal means is "washed" through legitimate systems and enterprises in order that it is cleaned and eventually returned to the criminal in the form of legitimate money.

Point 2.
This is the process by which criminals attempt to disguise the illegal origin of the proceeds of their criminal activities and to introduce those proceeds into the financial system as legitimate funds. As financial crime has become more complex, and "Financial Intelligence" (FININT) has become more recognized in combating international crime and terrorism, money laundering has become more prominent in political, economic, and legal debate. Money laundering is ipso facto illegal; the acts generating the money almost always are themselves criminal in some way (for if not, the money would not need to be laundered).

Point 3.
This is the process by which criminals attempt to disguise the illegal origin of the proceeds of their criminal activities and to introduce those proceeds into the financial system as legitimate funds. As financial crime has become more complex, and "Financial Intelligence" (FININT) has become more recognized in combating international crime and terrorism, money laundering has become more prominent in political, economic, and legal debate. Money laundering is ipso facto illegal; the acts generating the money almost always are themselves criminal in some way (for if not, the money would not need to be laundered).

What is Terrorist Financing?
Point 1.
Terrorist financing: Often linked in legislation and regulation, terrorist financing and money laundering are conceptual opposites. Money laundering is the process where cash raised from criminal activities is made to look legitimate for re-integration into the financial system, whereas terrorist financing cares little about the source of the funds, but it is what the funds are to be used for that defines its scope.

Point 2.
Terrorist financing may not necessarily involve the proceeds of criminal conduct. Rather the aim is to conceal the origin and/or intended use of the funds for criminal purposes i.e. to fund terrorists or terrorist activity.

Point 3.
Terrorist financing is generally involves the movement of funds by terrorists and terrorist groups in order to support their activities. Terrorist financing can involve the movement of funds derived from legal activity as well as funds derived from illegal activity. The movement of legitimate funds into the control of terrorist organizations is sometimes known as "reverse money laundering"

Large principal money transfer (LPMT): An LPMT refers to a principal send transaction that is generally over AUS$10000. This limit is set by SBX Money Pty Ltd and may be changed at its discretion.

SBX Money Pty Ltd aims to identify and act on preventing anti-money laundering and terrorism financing. We are subject to, and comply with all Australian laws relating to Anti-Money laundering and terrorism financing.

Also, we comply with Anti Money Laundering Act, 2002 (Act No. VII of 2002) in terms of section 2, of Bangladesh who is the one of main transaction country of this business.

Business Background:
A) We wish to clarify that Sonar Bangla Express has been doing remittances for four years, the intention being that it has operated on behalf of SBX Money Pty Ltd., which was not registered at the time. Its business has increased to a point where the transfer of the business of Sonar Bangla Express to SBX Money Pty Ltd is necessary to enable the commencement of SBX Money Pty Ltd. from an established position, in line with previous correspondence.
B) Sonar Bangla Express has been carried on by Mr. Shafique Chowdhury, a director and 50% shareholder in SBX Money Pty Ltd. He brings his specialised experience to the new company.

Business Information:
Business Name: SBX Money Pty Ltd.
ACN : 145 767 666
Head Office :
10/26 Burrows Rd , St Peters.
NSW-2044,Sydney, Australia.
Business Status: Company
Contact: Shafique Chowdhury
Phone: +61 2 9517 4021 Fax: +61 2 9517 4966
Mobile 1:+61 4 03 034 223 (Mr Shafique Chowdhury)
Email: shafique@sbxmoney.com.au

How Money laundering System works ?
Send:
Sending is the process where attempt is being made to transfer the funds through the financial system without attracting attention.

Distribution:
This is one of the clever processes of sending funds. In this process funds are moved around to break the investigative trail. This movement often involves a complex series of transactions to create confusion and complicate the paper trail.

Investment :
Investment which helps maximising the money laundering process. Once the funds are placed into the financial system and are scattered in the distribution stage.

more transactions are being made to create an impression of the legality. The idea is to make more transactions to provide a legitimate explanation for the source of the funds.

How do money launderers avoid suspicion?
Placement: Placement is the attempt to place funds in the financial system without attracting attention.

Layering: Layering is the stage of the money laundering process where funds are moved around to break the investigative trail. This movement often involves a complex series of transactions to create confusion and complicate the paper trail.

Integration: Integration is the ultimate goal of the money laundering process. Once the funds are placed into the financial system and are hidden in the layering stage, additional transactions are used to create the appearance of legality. These transactions attempt to provide a plausible explanation for the source of the funds.

Suspicion :
Suspicion means that, we suspect that a customer is using or seeking to use our money express services to launder money or finance terrorism and one of the following conditions is met:

  • We suspect on reasonable grounds that the customer is not the person they claim to be
  • We suspect on reasonable grounds that an agent of the customer is not who they claim to be
  • We suspect on reasonable grounds that information Sonar Bangla Express has concerning the provision, or prospective provision, of a designated service
  • May be relevant to investigation of, or prosecution of a person for evasion, or an attempted evasion, of a taxation law
  • We suspect on reasonable grounds that the provision, or prospective provision, of the service is preparatory to the commission of an offence connected to money laundering