Brumby Finance Pty Ltd, trading as Brumby Pay, confirms that it is not a provider of Designated Services under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (“AML/CTF Act”) and is therefore not a reporting entity under AUSTRAC.

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Brumby Pay operates purely as a Software-as-a-Service (SaaS) platform. We provide secure digital tools that allow businesses to monitor voluntary invoice payment activity, automate compliant communication, and offer deterministic, milestone-based recognition, for example, awarding a fixed-value reward to the 100th invoice payer. These services are administrative in nature and do not constitute financial, credit, or payment services.

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Brumby Pay does not receive, hold, move, or disburse funds on behalf of any party. We do not act as an agent, custodian, or trustee, nor do we facilitate remittance, escrow, or stored value systems. Brumby Pay does not offer BNPL, credit, or lending products, and we do not engage in collections, enforcement, or inducement of payment. All invoice payments are processed by regulated third-party payment providers, each of which maintains their own AML/CTF compliance obligations under AUSTRAC.

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Following legal review, Brumby Pay confirms it does not engage in any activities that constitute a Designated Service under the AML/CTF Act or Rules.

 

As such, Brumby Pay’s operations fall entirely outside the scope of AUSTRAC’s Designated Services.

We conduct ongoing reviews of our business model and system workflows to ensure continued compliance.

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Contact:
For any questions regarding Brumby’s AML/CTF classification or non-designation status, please contact:
Compliance Officer
support@brumbypay.com.au
Brumby Finance Pty Ltd
 

If you are unsure about the nature of our services or your compliance obligations, please seek independent legal advice.

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