Australian Financial Services Licensing (AFSL) Forum


Paul Derham

As we understand it, Authorise and Capture Payment is a method by which a person will Authorise payment, in which both their ADI and the remitter will be notified of an intent to transfer funds, and Capture is the point in the transfer when the funds are received into the remitter’s own account.


On this question, we are presuming that you are operating an electronic money remittance service, and that the “48 hour window” is the 2 business days listed in the Corporations Regulations during which you must remit the funds.


The Regulations exempt some financial products from AFS licensing requirements where the money is made available to the client or their nominated beneficiary within 2 business days of receiving the client’s instruction, among other requirements. This would imply that the time constraint commences at the point of Authorisation rather than the point of Capture.


However, your Terms and Conditions may set out a different point at which instructions are received, which will give a different point from which the 2 business days are calculated.


Please feel free to contact our financial services team if you would like further assistance.


Authors: Paul Derham (Partner)

Co-contributor: Hugo Sasse (Law Clerk)


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