Revolut's $187,800 fine. How did they mess up?

When I first started diving into the world of Australian compliance, it felt like learning a new language filled with acronyms. But as I’ve gotten deeper, I’ve realised that behind every rule and every three-letter abbreviation is a crucial piece of the puzzle designed to protect Australia from financial crime. It’s a fascinating and high-stakes field where getting the details right is everything.

One of the first areas I had to get my head around was the different types of reports that companies must send to AUSTRAC, the government’s financial intelligence agency. Three of the big ones that form the backbone of the system are:

• Threshold Transaction Reports (TTRs): This is the “big cash” report. Anytime a customer makes a transaction involving $10,000 or more in physical cash (or the foreign equivalent), a report is automatically sent to AUSTRAC. It’s a simple rule to track large amounts of physical currency, which is often used by criminals.
• Suspicious Matter Reports (SMRs): This is the “detective” report. It’s not about the amount of money, but the context. If a transaction or a customer’s behaviour raises a red flag—even for a small amount—the business has a legal duty to report their suspicions. It’s the financial world’s version of “see something, say something.”
• International Funds Transfer Instruction (IFTI) Reports: This is the “border crossing” report. Every time money is sent into or out of Australia electronically, an IFTI report must be filed with AUSTRAC. This gives the agency a clear view of the money flowing across our borders, allowing them to spot unusual patterns that could indicate money laundering or terrorism financing.

It’s this last one—the IFTI—that recently landed fintech giant Revolut in hot water, and for me, it served as a powerful real-world lesson.

So, How Did Revolut Mess Up?

Revolut’s issue wasn’t with a complex, sophisticated crime. It was with the fundamentals of the IFTI reporting process. The rule is simple: when you process an international money transfer, you have 10 business days to file the IFTI report with AUSTRAC.

According to the official infringement notice, on 10 separate occasions, Revolut failed to file these crucial reports on time.

The fine was calculated very simply:

• Penalty per missed report: $18,780
• Number of missed reports: 10
• Total Fine: $187,800

For someone like me, learning the ropes of compliance, this was a lightbulb moment. The fine wasn’t for letting a criminal mastermind slip through the net; it was for repeatedly failing to do the required paperwork on time. It shows that AUSTRAC takes the basic operational duties just as seriously as the more direct crime-fighting ones.

Why This Matters More Than You’d Think

A $187,800 fine might seem like a drop in the ocean for a global company, but this failure highlights a critical point I’m coming to appreciate: consistency and attention to detail are paramount.

• It Creates Gaps in National Security: Each IFTI report is a small piece of a giant puzzle. When reports are late or missing, it leaves holes in the data that authorities use to protect Australia from criminals and terrorists.
• It Shows a Potential Process Failure: For customers, a repeated error raises questions about a company’s internal processes. If a mandatory reporting system fails 10 times, it suggests a potential weakness in the operational nuts and bolts of the business.
• It Undermines the System’s Integrity: The entire anti-financial crime system relies on every institution doing its part accurately and on time. When one company fails to report correctly, it weakens the safety net for everyone.

How Could This Have Been Prevented? A Lesson for Us All

As I continue my journey in this field, this case has become a powerful lesson in operational excellence. Preventing these kinds of breaches comes down to more than just having good intentions; it requires flawless execution.

• Automate and Test Your Reporting: The best way to prevent human error or delays in routine reporting is to automate the process as much as possible. A robust system should automatically flag transactions for reporting and submit the data to AUSTRAC. Crucially, these systems must be regularly tested.
• Make Compliance a Core Business Priority: For fast-moving fintechs, there can be a temptation to prioritize growth above all else. This case shows that compliance can’t be an afterthought. It must be woven into the company culture from the executive team down.
• Invest in People and Local Expertise: Automation is a powerful tool, but it isn’t a silver bullet. You need skilled people to oversee the systems, investigate anomalies, and understand the specific local laws of every country you operate in.

The Revolut fine has been a stark reminder for me that in the world of finance, “close enough” is never good enough. For fast-growing companies, the lesson is clear: your operational and compliance capabilities must scale at the same pace as your customer base. Getting the small, repetitive details right isn’t just about avoiding fines—it’s about building a sustainable, trustworthy business. It’s a lesson I’ll carry with me as I go deeper into this fascinating field.

Click to read AUSTRAC’s media release.