Section 01
Purpose
This policy establishes Partner Plus's commitment to preventing the facilitation of money laundering and terrorism financing across all operations. It sets out the internal controls, monitoring systems, reporting procedures and governance standards required to protect the integrity of Partner Plus, its clients and the broader financial system.
This Policy Exists To
- Prevent Partner Plus from being used — knowingly or unknowingly — to facilitate money laundering or terrorism financing.
- Ensure compliance with applicable AML/CTF legislation and regulatory obligations, including AUSTRAC requirements where applicable.
- Protect the reputation, financial integrity and operational standing of Partner Plus.
- Establish clear internal controls, escalation pathways and reporting responsibilities for all staff.
Section 02
Scope
This policy applies broadly across the Partner Plus business. Any person operating within or on behalf of Partner Plus, and any activity involving the movement or conversion of value, falls within its scope.
This Policy Applies To
Covered Activities
Section 03
Key Definitions
All staff must be familiar with the following terms. Uncertainty about any definition should be escalated to the Compliance Officer immediately.
Money Laundering
The process of concealing the origins of illegally obtained money to make it appear legitimate through a series of transactions or conversions.
Terrorism Financing
The collection or provision of funds — whether from legitimate or illegitimate sources — intended to support terrorist acts or organisations.
Customer Due Diligence (CDD)
The verification procedures used to confirm customer identity and assess the level of risk associated with that customer and their transactions.
Enhanced Due Diligence (EDD)
Additional verification measures applied to higher-risk customers, including Politically Exposed Persons (PEPs) or where standard CDD raises concerns.
Suspicious Matter (SM)
Any transaction, behaviour or activity that appears inconsistent with a customer's known profile, stated purpose or business type — or that may indicate criminal activity.
Politically Exposed Person (PEP)
An individual who holds or has held a prominent public position, or is a close associate of such a person, and therefore presents an elevated risk of bribery or corruption.
Tipping-Off
The act of informing a customer — directly or indirectly — that a suspicious matter report has been filed or is under consideration. This is strictly prohibited under AML/CTF legislation.
Section 04
Risk Assessment Framework
Partner Plus adopts a risk-based approach to AML/CTF compliance. This means resources and controls are proportionate to the level of risk identified. Higher-risk activities, customers and channels attract enhanced controls automatically.
Product Risk
Points & Reward Conversion
- Points converted into high-value goods or services
- Bulk or rapid points redemption activity
- Non-marketplace (manual) allocations
- High-value single redemptions
Customer Risk
Member Profile Anomalies
- New customers with unusually high earning velocity
- Dormant accounts suddenly transacting at volume
- Complex corporate structures or beneficial ownership
- Identified or suspected Politically Exposed Persons (PEPs)
Transaction Risk
Unusual Transaction Patterns
- Large redemptions inconsistent with the member's business profile
- Repeated small redemptions structured to avoid internal thresholds
- Unusual geographic purchasing patterns
- Requests for non-standard payment or delivery routing
Channel Risk
Delivery Method Risk
- Concierge-assisted redemptions involving large or unusual allocations
- Manual overrides or discretionary adjustments to points balances
- Off-marketplace offer fulfilment outside standard system controls
Section 05
Customer Identification & Due Diligence
Partner Plus verifies the identity of all business clients at onboarding and applies enhanced scrutiny where risk indicators are present. No anonymous accounts are permitted under any circumstances.
Standard CDD — Required at Onboarding
- Legal business name — verified against ABN/ASIC registration
- ABN or Company Registration Number
- Registered business address
- Director identification — required where transactions involve financial decision-making above thresholds
- Authorised representative verification — required for concierge interactions involving large allocations or off-marketplace offers
Enhanced Due Diligence (EDD) — Applied Where
- High-value redemptions exceed the internal threshold set by the Compliance Officer
- The customer's profile, behaviour or transaction pattern appears inconsistent
- PEP status is identified or reasonably suspected
- Standard CDD raises unresolved concerns
Absolute Rule
No anonymous accounts, anonymous redemptions or unverified high-value transactions will be processed under any circumstances. Where identity cannot be confirmed, the transaction must be paused and escalated to the Compliance Officer immediately.
Section 06
Ongoing Transaction Monitoring
Monitoring is continuous — not a one-time check at onboarding. Partner Plus maintains active oversight of transaction activity to detect emerging risk patterns over time.
What We Monitor For
- Unusual points earning patterns or velocity spikes
- Unusual or accelerated redemption activity
- Multiple account linkages or shared identifiers
- Suspicious manual balance adjustments
- Requests for unusual payment routing or delivery
How We Monitor
- Automated transaction flags where system capability allows
- Monthly manual review of all high-value transactions
- Concierge escalation process for irregular behaviour identified on calls
- Periodic Compliance Officer review of activity reports
Section 07
Suspicious Matter Reporting
Every employee has a personal obligation to report suspicious behaviour. Reporting is not optional — failure to escalate a known or suspected suspicious matter is a serious breach of this policy.
Tipping-Off Prohibition — Mandatory
Under AML/CTF legislation, it is a criminal offence to inform a customer — directly or indirectly — that a Suspicious Matter Report has been filed or is being considered. Under no circumstances may any employee disclose this to a customer. If you are uncertain, say nothing and escalate immediately.
Examples of Suspicious Behaviour to Report
- A member requesting conversion of points into cash equivalents outside approved policy
- Patterns suggesting attempted resale of redeemed goods
- Attempts to structure redemptions to stay below internal thresholds
- Refusal to provide identity verification when reasonably requested
- Unusual urgency around large or non-standard transactions
- Third parties attempting to direct or influence a member's redemption decisions
Reporting Process
01
Immediate Escalation
Report the matter to the Compliance Officer immediately — verbally first, followed by written documentation. Do not attempt to investigate or resolve the matter independently.
02
Compliance Officer Assessment
The Compliance Officer assesses the matter, gathers available information and determines whether a formal Suspicious Matter Report (SMR) is required.
03
Regulatory Reporting
Where required, the Compliance Officer lodges a Suspicious Matter Report with the appropriate regulatory authority — including AUSTRAC where Partner Plus qualifies as a reporting entity.
04
Confidentiality Maintained
All reporting is handled with strict confidentiality. The tipping-off prohibition applies to all employees at every stage. The existence of a report must never be disclosed to the subject.
Section 08
Record Keeping
Comprehensive, accurate and secure record keeping is both a legal obligation and a fundamental operational requirement. All records must be retained for a minimum of 7 years from the date of the relevant transaction or activity.
Records to Be Retained
- Customer identification and verification records
- Transaction records — all value movements
- Concierge call notes relating to high-value allocations
- Suspicious matter reports and supporting documentation
- Risk assessments — initial and ongoing
- Staff training completion records
Record Security Standards
- All records stored securely with access restricted to authorised personnel
- No records to be destroyed before the 7-year minimum retention period
- Records must be readily accessible to the Compliance Officer and, where required, regulatory authorities
- Digital records must be backed up and protected from unauthorised modification
Section 09
Governance & Responsibility
AML/CTF compliance is a shared responsibility — but accountability is clearly assigned. Every person within scope of this policy has a defined role to play.
Role
Responsibilities
Board / Director
- Approve and maintain the AML/CTF framework at board level
- Ensure adequate resources are allocated for compliance activities
- Review policy annually and following any material risk event
Compliance Officer
- Maintain, update and implement the AML/CTF program
- Conduct and document risk assessments
- Review and action all suspicious matter escalations
- Oversee regulatory reporting obligations including AUSTRAC
- Conduct annual policy review and recommend updates
- Oversee staff training completion and documentation
All Employees & Concierge Staff
- Complete mandatory AML/CTF induction and annual refresher training
- Escalate any suspicious behaviour immediately to the Compliance Officer
- Follow all customer verification procedures without exception
- Document high-risk transactions accurately and completely
- Never tip off a customer that a report has been filed
Section 10
Training Requirements
No employee may operate within the scope of this policy without completing the required training. Training completion is mandatory and must be documented. It is the Compliance Officer's responsibility to ensure all records are maintained.
1
AML/CTF Induction Training
Completed before commencing any activity within scope of this policy. Covers definitions, obligations, escalation pathways and record-keeping requirements.
2
Annual Refresher Training
Completed every 12 months by all relevant staff. Updated to reflect any regulatory changes, internal policy updates or lessons from the prior year.
3
Concierge-Specific Red Flag Training
Specific training for all concierge and program management staff covering behavioural red flags during member interactions, escalation triggers and the tipping-off prohibition.
4
Training Documentation
All training completions must be recorded with date, staff member name and training type. Records retained for a minimum of 7 years.
Section 11
Internal Controls & High-Value Redemptions
Operational controls exist to reduce the risk of AML/CTF breaches at the transaction level. These controls are mandatory and cannot be bypassed without Compliance Officer approval.
Standard Internal Controls
- Segregation of duties between approval and processing functions
- Threshold-based approval requirements for high-value redemptions
- Restricted access to manual points balance adjustments
- Full audit trails for all concierge-assisted allocations
- Periodic internal compliance reviews by the Compliance Officer
High-Value Redemption Protocol
- Identity reconfirmation required above the internal threshold
- Secondary approval by Compliance Officer or Senior Manager
- Written documentation of business rationale required
- Ongoing monitoring for repeat behaviour patterns
Independent Review
An independent review of the AML/CTF program will be conducted at least every 2–3 years, or earlier if required by law or following identification of a material risk event or breach.
Section 12
Breaches & Policy Review
Consequences of Non-Compliance
Non-compliance with this policy is treated as a serious matter. Depending on the nature and severity of the breach, consequences may include formal disciplinary action, termination of employment or engagement, and mandatory regulatory reporting to AUSTRAC or other relevant authorities.
Policy Review Schedule
- Annually — standard review conducted by the Compliance Officer
- Upon regulatory change — immediate review and update required
- Following a material risk event or breach — triggered review within 30 days
If Partner Plus Qualifies as a Reporting Entity Under AML Legislation
- A formal AML/CTF Program (Part A & Part B structure) will be required.
- Threshold Transaction Reporting procedures must be established.
- Sanctions and PEP screening processes must be implemented.
- Terrorism financing risk mapping must be completed.
- A designated AML/CTF Compliance Officer must be formally registered with AUSTRAC.