Fair points.
I did indeed get my wires crossed.
AUSTRAC does not seem that concerned with money laundering or terrorism funding from BNPL as "BNPL loans cannot be repaid with cash, and in fact need to be repaid via credit or debit card. This may reduce the risk of money laundering because it means transactions will be monitored by two reporting entities."
Source: https://www.austrac.gov.au/sites/default/files/2021-06/AUSTRAC_RiskAssessment2021_NonBankLenders.pdf
Austrac scrutinising Afterpay, page-58
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