The Australian Gift & Prepaid Card Association (AGPCA) has submitted a formal application to AUSTRAC seeking clarification on how recent legislative amendments apply to gift cards and other stored value card products.
The Anti Money Laundering and Counter Terrorism Financing Amendment Act 2024 introduced updated provisions relating to “transfers of value” under items 29 and 30 of the AML/CTF Act. While these provisions are primarily intended to consolidate rules relating to wire transfers and remittance services, the new wording has created uncertainty about whether they could also be interpreted to apply to gift cards.
Gift cards, both closed loop and open loop, have always operated under the dedicated stored value card provisions (items 21–24), which include established de minimis thresholds and long standing AML/CTF treatment appropriate for low value, consumer focused payment products.
What AGPCA is seeking
The AGPCA’s submission requests a clear exemption confirming that:
• The new “transfer of value” provisions are not intended to regulate the sale or activation of gift cards, and
• Gift cards continue to be governed exclusively under the existing stored value card framework.
This clarification is essential to maintain regulatory certainty and to avoid interpretations that could make it impractical, or even impossible, for gift card issuers and retailers to operate in Australia. Requirements such as KYC at point of sale or recipient identification are incompatible with the gifting nature of the product and would create friction that undermines consumer usage and retailer participation.
Why this matters
Gift cards are an important, established part of Australia’s retail ecosystem. Ensuring the regulatory settings remain proportionate and fit for purpose:
• Protects a thriving industry that delivers significant economic activity
• Avoids unnecessary compliance burdens for retailers and issuers
• Maintains alignment with global FATF recommendations for low value prepaid products
• Ensures consumers continue to enjoy simple, accessible gifting options
Advocacy on behalf of members
This exemption request is part of AGPCA’s broader work to support a sustainable and compliant gift card industry. Members receive exclusive access to the full submission, detailed analysis, updates from AUSTRAC, and ongoing engagement with regulators.
Organisations involved in issuing, selling, distributing, or managing gift cards are encouraged to join the AGPCA to stay ahead of regulatory developments and help shape the future of the industry.