AML/CTF Policy
Last updated: November 30, 2025
TL;DR Summary
We provide creative consulting and design concept services only. We do not accept cash payments and may require identity verification for high-value transactions. We monitor for suspicious activity and maintain records for 7 years. We report suspicious matters to AUSTRAC as required by law.
1. Introduction
Sterling Design Group PTY LTD (ABN: 81 689 272 535) is committed to preventing money laundering and terrorism financing activities. This Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Policy outlines our approach to compliance with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and related regulations.
2. Our Services
Important: Sterling Design Group provides creative consulting and design strategy services only. We do not:
- Handle physical goods or products
- Provide financial services or advice
- Facilitate money transfers or currency exchange
- Act as a financial intermediary
- Provide services that typically require AUSTRAC registration
Our services are limited to creative strategy, brand concepts, graphic design direction, environmental design concepts, and creative advisory services.
3. Payment Methods
We accept payments through the following methods:
- Credit card payments (Visa, Mastercard) processed securely by our payment service provider
- Bank transfers for larger amounts
- Digital payment methods through secure third-party processors
We do not accept cash payments under any circumstances.
4. Customer Due Diligence
4.1 Standard Procedures
For all clients, we collect and verify:
- Full name and contact details
- Company information (if applicable)
- Business address and contact information
- Service requirements and project scope
4.2 Enhanced Due Diligence
For high-value transactions (AUD $10,000 or more) or suspicious circumstances, we may require:
- Government-issued photo identification
- Proof of business registration (ABN/ACN)
- Source of funds documentation
- Additional verification as deemed necessary
5. Suspicious Activity Monitoring
We monitor transactions and client interactions for the following red flags:
- Unusual payment patterns or methods
- Requests for services inconsistent with our business model
- Reluctance to provide standard business information
- Complex or unusual transaction structures
- Requests to process payments for third parties
- Inconsistent or suspicious client behavior
6. Record Keeping
We maintain comprehensive records of all client interactions, transactions, and due diligence activities for a minimum of 7 years from the date of the transaction or relationship termination, as required by Australian law.
Records include:
- Client identification and verification documents
- Transaction details and payment records
- Service agreements and project documentation
- Communication records and correspondence
- Suspicious matter reports (if applicable)
7. Suspicious Matter Reporting
If we identify suspicious activity that may be related to money laundering or terrorism financing, we will:
- Immediately suspend the transaction or relationship
- Conduct additional due diligence
- Report the matter to AUSTRAC within 24 hours
- Maintain confidentiality of the report
- Cooperate with law enforcement if required
8. Prohibited Uses
Our services may not be used for:
- Money laundering or terrorism financing
- Fraudulent or illegal activities
- Circumventing financial regulations
- Processing payments for prohibited entities
- Any activity that violates Australian law
9. Staff Training
All staff members receive training on AML/CTF obligations, including recognition of suspicious activity, customer due diligence procedures, and reporting requirements. Training is updated regularly to reflect changes in legislation and best practices.
10. Compliance Monitoring
We regularly review and update our AML/CTF procedures to ensure ongoing compliance with Australian law. This includes monitoring changes in legislation, industry best practices, and emerging risks.
11. Contact Information
For questions about this AML/CTF Policy or to report suspicious activity, please contact us:
Sterling Design Group PTY LTD
Email: support@sd-design.shop
Location: Woodcroft, SA, Australia
ABN: 81 689 272 535
12. Policy Updates
This AML/CTF Policy may be updated from time to time to reflect changes in legislation or our business practices. We will notify clients of material changes and maintain version control of all policy documents.