Stored Value Cards Industry Consultation Paper 2026
Submission Date: 23 October 2026
The Financial Services Committee of the Business Law Section of the Law Council of Australia (the Committee) appreciates the opportunity to provide its views on the proposal to reduce the applicable thresholds to regulation set out in the Stored Value Cards – Industry Consultation Paper 2026 (the Paper).
The Committee notes that the 2016 Statutory Review of the AML/CTF Act conducted by the Attorney-General’s Department recommended that AUSTRAC assess the money laundering/terrorism financing (ML/TF) risks posed by stored value cards (SVCs) and the continued appropriateness of the thresholds for SVC designated services (recommendation 4.3). The 2017 AUSTRAC Stored Value Cards ML/TF Risk Assessment analyses the vulnerabilities of the product, including the particular vulnerabilities associated with “below the threshold” SVCs.
The Committee considers that the choice of threshold of monetary value above which SVCs are regulated as designated services under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act) is unlikely on its own to materially impact the ML/TF risk of the SVC product. The impact of Chapters 5 and 6 of the Anti-Money Laundering and Counter-Terrorism Financing (Class Exemptions and Other Matters) Rules 2007 (Cth) (Exemptions Rules) on SVC ML/TF risk and the viability of the industry has the potential to be greater.
Items 21 to 24 of Table 1 at section 6 of the AML/CTF Act relate to the issuing or reloading of SVCs either with, or without, the facility to withdraw cash from the card. Chapters 5 and 6 of the Exemptions Rules have the effect of ensuring that merchants are able to accept gift cards under the relevant threshold of monetary value in certain circumstances without triggering AML/CTF obligations.
The Committee considers that Chapters 5 and 6 of the Exemptions Rules should be considered in conjunction with any change in the monetary value of the thresholds set out in items 21 to 24 of Table 1 at section 6 of the AML/CTF Act in order to effectively address the ML/TF risks of SVCs and ensure the viability of the industry for the continued availability of SVC products to consumers.
Last Updated on 29/10/2026
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