AML/KYC policy
Version 0.2 (draft for review) · effective TBC
This is a public summary of our anti-money-laundering and counter-terrorism financing (AML/CTF) program. It explains what we check, when, and why. It isn’t the full program, and it doesn’t change our terms of service.
1. Why we have this policy
A business address can be misused: to hide who really owns or controls a company, to set up shell or phoenix companies, or to make a scam look legitimate. Since 1 July 2026, providing a registered office or principal place of business address to a company or other legal arrangement has been a service regulated by the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth). Businesses that provide it must verify their customers, monitor them, keep records, and report suspicious matters to AUSTRAC, the Australian regulator.
Dee Bee Vee Pty Ltd, which runs MailStreet, is the reporting entity for these obligations. We apply the same checks to every customer, including sole traders, so that the same protections apply to everyone using our address.
2. When we check
- Before your address is released. You pay at sign-up, but we don’t release your address, issue any documents or accept any mail until every required check passes.
- If checks don’t pass, or aren’t completed within 14 days, we cancel and refund you in full, including any $15 verification fee.
- When something changes, such as a new director, owner or trustee.
- Throughout the relationship, through the ongoing monitoring described below.
3. Who we verify
| Customer | Who we verify |
|---|---|
| Sole trader | The individual. |
| Proprietary (Pty Ltd) company | The person signing up (and their authority to act), every director, and anyone who owns or controls 25% or more. If nobody holds 25%, the most senior managing official. |
| Trust | Individual trustees, or the owners and directors of a corporate trustee; the appointor, protector and anyone else who controls the trust; and the person signing up. We also record the settlor and the classes of beneficiaries. |
| Partnership or other arrangement | Partners who own or control 25% or more, and the person signing up. |
| Public company | By request only, after an individual review. |
| Foreign company, or any business run from overseas | As for a company, always with a manual review and enhanced checks. |
Each person we need to verify gets their own secure link by email, so they don’t have to share their ID with the person signing up.
4. What we check
- Identity. A current government photo ID (such as a driver licence or passport), checked for authenticity, with a liveness check and a face match to confirm the person holding it is its owner. Where available, and with consent, the document is also checked against government records through the Document Verification Service.
- Screening. Every person is screened against sanctions lists, politically exposed person (PEP) lists and adverse media.
- The business. An active ABN through the Australian Business Register, with the name matched to the ID. For companies, a current ASIC extract to confirm the company’s status, directors and shareholders. For trusts, a full copy of the trust deed, including any amendments.
- Beneficial ownership. Who ultimately owns or controls 25% or more of the business, including through other companies or trusts.
- How you’ll use the address. Your intended uses, your actual operating address, the nature of your business and the mail you expect.
Identity checks and screening are carried out for us by our verification provider, Didit. Our privacy policy explains how that information is handled, including biometric information.
5. When we need more
Most applications are approved automatically once every check passes. A member of our team reviews an application, and may ask for more information or carry out enhanced checks, where for example:
- a person matches a sanctions, PEP or adverse media list;
- directors or owners are overseas, or the business is run from overseas;
- ownership is complex, or involves nominee or corporate shareholders;
- names or addresses don’t match across documents;
- the company is less than 30 days old;
- an ID check fails or needs several attempts; or
- the business is in an industry we consider higher risk.
Enhanced checks can include asking about the business’s activities, its owners or the source of its funds, and asking for further documents. A review doesn’t mean we suspect you of anything. We usually finish within 2 business days of receiving everything we need.
6. Ongoing monitoring
- Everyone we’ve verified is re-screened against sanctions, PEP and adverse media lists daily.
- We re-check ABN and ASIC details each year, and ask you to confirm your details.
- A change of director, owner, trustee or partner means fresh checks on the new people.
- We look for unusual patterns in the outside of your mail, using our mail log: for example, large volumes of mail from courts, debt collectors or liquidators, mail for many different names, lots of returned mail, forwarding to high-risk countries, or a plan change and address change close together. We don’t open mail to do this.
7. What we ask of you
- Give us true and complete information.
- Tell us within 14 days about changes to your people, ownership, business details or operating address.
- Respond to our requests for information within a reasonable time.
- Use the address only for the businesses and people on your account.
8. Holds, refusals and closures
We may, at our discretion:
- decline an application;
- hold your mail, or stop you using the address, while we carry out a review; and
- close an account, including if you don’t give us information we ask for.
We may not be able to give reasons. The law restricts what we can say about some decisions, and we don’t promise to explain why we’ve declined, held or closed an account. If we decline an application, you still get a full refund. If we close an account, our terms explain what happens to your mail and any prepaid fees.
9. Reporting and confidentiality
We report suspicious matters and other information to AUSTRAC as the law requires. The law prohibits us from disclosing whether we have made, or are considering making, a report. AML information is restricted to our compliance officer; general staff can’t see it.
10. Record keeping
We keep records of our checks, the information and documents we relied on, our risk assessments and decisions, and our mail log for 7 years after a customer relationship ends, or after an application ends if it doesn’t go ahead. We can’t delete these records early, even on request. They’re stored securely in Australia, and every access is logged.
11. How we run our program
- Our program is approved by our senior management and overseen by a nominated AML/CTF compliance officer.
- It is based on a written assessment of the money laundering and terrorism financing risks of our service.
- Staff who handle mail or customer information are screened before they start and trained in our obligations.
- We review the program regularly, and it is independently evaluated as the law requires.
12. Questions
Questions about our checks? Email hello@mailstreet.com.au.