AUSTRAC has cancelled an Enforceable Undertaking (EU) from PayPal Australia Pty Ltd after PayPal completed a two year remediation plan to improve its systems and controls relating to international funds transfer instructions (IFTIs).

In 2020 AUSTRAC ordered an external audit of PayPal’s AML/CTF program, after it identified significant concerns that PayPal’s systems, controls and governance were not appropriate for the size and complexity of PayPal’s business and the money laundering risks to which it was exposed.

Following the external audit, AUSTRAC accepted an EU from PayPal in March 2023 which sought to rectify compliance issues in the reporting of IFTIs that deprived our partners of timely financial intelligence.

In May 2025, PayPal advised AUSTRAC it had completed the remediation work required under the EU, and had carried out additional work on its controls outside of the EU, which were recommended following an external audit. Both the external auditor and AUSTRAC have agreed that PayPal has improved its practices in line with the requirements of the EU.

AUSTRAC CEO Brendan Thomas commented:

“If, like PayPal, your systems and controls do not match the size and complexity of your business, and the risks you face, your business will be exposed to unmitigated risks. Simply put, you may be inadvertently moving the proceeds of crime for a criminals.

Then we will take action.”