Introduction and Scope
Sendrato Australia Pty Ltd(ABN 98 605 555 833) ("Sendrato," "we," "our," or "us") operates the Ludo Leisure Suite platform, which processes payments, wallet loads, and redemptions at events and venues. We recognise the inherent risk that payment products can be exploited for money laundering or terrorism financing, and we are committed to complying with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act), associated rules, and the oversight of the Australian Transaction Reports and Analysis Centre (AUSTRAC).
This policy applies to all Sendrato business divisions and personnel, and to third-party service providers who perform designated services on our behalf, both in Australia and overseas.
Definitions
- Money Laundering means the act of disguising the origins of illegally obtained funds.
- Terrorism Financing means the act of providing financial support to terrorist activities.
- Designated Service has the meaning given in the AML/CTF Act.
- AUSTRAC means the Australian Transaction Reports and Analysis Centre.
Customer Identification
Before engaging in any designated service, customers are required to provide proof of identity. The types of customers we deal with include:
- Individuals
- Sole Traders
- Domestic and Foreign Companies
- Partnerships
- Trusts
- Associations
- Registered Co-operatives
- Government Bodies
Identification may be verified using government-issued identity documents, the Australian Government's Document Verification Service (DVS), or through an accredited identity verification provider. Records of verification are retained for 7 years from the date of the relevant transaction or verification event.
Relationship with Payment Partners
Sendrato operates the Ludo Leisure Suite under commercial arrangements with AUSTRAC-regulated payment acquiring partners. Card and bank settlement is performed by our acquiring partners under their own AML/CTF programs. Sendrato maintains this policy and its own program to govern our operational controls, staff responsibilities, transaction monitoring, and reporting obligations in connection with the designated services we provide.
Suspicious Matter Reporting
Our personnel are trained to identify and escalate any suspicious activities that may indicate money laundering or terrorism financing. Where a suspicious matter is identified, it is reported to our AML/CTF Compliance Officer and, where required, to AUSTRAC in accordance with the AML/CTF Act.
Key AML/CTF Principles
- Comply with AML/CTF legislation in the jurisdictions where we operate.
- Meet or exceed accepted international standards.
- Cooperate with AUSTRAC and other governmental bodies.
- Make decisions based on our money laundering and terrorism financing risk appetite, and our obligations to customers and the community.
- Maintain and comply with an AML/CTF program, including ongoing staff training and independent review.
Roles and Responsibilities
Sendrato's Directors and Senior Management oversee this AML/CTF policy. An AML/CTF Compliance Officer is appointed to manage the day-to-day program, including risk assessment, transaction monitoring, reporting, and training. All personnel must comply with this policy and complete role-specific training.
Monitoring and Reporting
We monitor transactions processed through the Ludo Leisure Suite for indicators of money laundering or terrorism financing. In conjunction with our payment acquiring partners we report:
- Threshold transaction reports where required under the AML/CTF Act;
- International funds transfer instructions where required;
- Suspicious matter reports where required.
Record Keeping
We retain AML/KYC verification records, transaction records, and related correspondence for at least 7 years from the date of the transaction or verification event, as required under the AML/CTF Act.
Contact
Questions about this policy may be directed to the AML/CTF Compliance Officer at Sendrato Australia Pty Ltd, 1044A Dandenong Rd, Carnegie VIC 3163, Australia, or gday@ludo.computer.