A simple enquiry to operational staff (this is publicly available information via account set-up questions) reveals that, like many companies, APT actually use a third party company (Illion) to do a credit check - there are a plethora of digital data companies using electoral role data to maintain credit scores on people, often to their ignorance - on the basis of your name, address and DOB.
If you have a healthy credit score you will not require further verification. If you do not they will require additional checks including photo ID proof.
For all those investors who have (wisely) set up an account to see if they have checks, the apparent absence of checks is actually due to your individual credit score being healthy (one would hope so if you are trading shares) and not a lack of checks by APT - they are doing a credit check in the background. Admittedly, this might not presently fulfil AUSTRAC's future 'know your client' requirements, but remember APT was formally classified as not being a credit provider via the Senate inquiry.
The recent Senate inquiry stopped short of recommending Afterpay and its competitors to be covered by the National Credit Act, which means they are not actually required to conduct responsible lending checks on consumers. They are actually preforming checks over and above what they have been advised they are legally required to do, at present.
It would surely be rather ridiculous for AUSTRAC to come over the top and late to the party after the Senate Committee looked at the 'buy now, pay later' (BNPL) industry and made rulings and recommendations (which Afterpay has been working on with ASIC), but then fine Afterpay for superfluous regulatory requirements that is was not formally advised are not required of it by the Senate inquiry or ASIC?
Under AUSTRAC's own remit, only Financial Services, Bullion and Gambling companies are required to perform regular mandatory reporting to them, and that for amounts over $10,000 (CBA was done for failing to report over 53,000 cash deposits of $10,000+ amongst other failings). Afterpay does not allow such large transactions. There are other requirements under AUSTRAC of course, but does anyone else think it would be a bit ridiculous after a Senate Inquiry only 4 months ago over regulation of the BNPL industry and 20 recommendations by the Committee, for AUSTRAC to fine them despite APT following those recommendations? I think APT would have a pretty clear defence and path of appeal in the courts that AUSTRAC failed in its duties during the inquiry if they try to bring a civil action on its failure of performing regulatory requirements that were omitted from the Senate inquiry. It would also make that inquiry a joke/failure.
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