This policy ensures that client complaints are managed fairly, efficiently, and transparently, in accordance with regulatory requirements, including the Australian Securities and Investments Commission (ASIC) guidelines and Australian Financial Complaints Authority (AFCA) standards. 

How to Lodge a Complaint

Clients may submit complaints through the following channels:

• Email: hayden@borrowe.com.au
• Phone: 0431 518 804
• Mail: 13 Grevillea Road, Bogangar NSW 2488

We encourage clients to provide as much detail as possible to facilitate a timely and effective resolution.

Complaint Resolution Process

1. Acknowledgment: Complaints will be acknowledged in writing within one business day of receipt.
2. Investigation: We will conduct a thorough review of the complaint, gathering relevant information and consulting all parties involved.
3. Response & Resolution: 
   • A formal response will be provided within 30 days of receiving the complaint.
   • If the complaint is complex and requires additional time, we will inform the client of the expected resolution timeline.
   • Resolutions may include corrective actions, compensation (if applicable), or explanations of decisions made.

Escalation to AFCA

If a complaint is not resolved to the client’s satisfaction, they may escalate the matter to the Australian Financial Complaints Authority (AFCA), which provides independent dispute resolution services.

• Website: www.afca.org.au
• Phone: 1800 931 678
• Mail: GPO Box 3, Melbourne VIC 3001

We regularly review complaints to identify patterns and areas for improvement. Internal training ensures staff remain informed on best practices for handling complaints. 

This policy ensures compliance with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act). It outlines our commitment to detecting, preventing, and reporting money laundering and terrorism financing activities.

Customer Identification

We implement a robust Know Your Customer (KYC) process, which includes:

• Collecting valid identification documents (e.g., driver’s license, passport, Medicare card).
• Verifying client identities using government and third-party databases.
• Conducting enhanced due diligence for high-risk clients.

Transaction Monitoring

We actively monitor financial transactions to identify suspicious activities, including:

• Large cash transactions exceeding regulatory thresholds.
• Unusual transaction patterns, such as rapid movements of funds.
• Transactions involving high-risk jurisdictions or entities with known financial crime associations.

Reporting Obligations

We comply with all reporting requirements under the AML/CTF Act, including:

• Suspicious Matter Reports (SMRs): Filed with AUSTRAC when we detect potentially      suspicious activities.
• Threshold Transaction Reports (TTRs): Submitted when transactions exceed $10,000 in cash.
• International Funds Transfer Instructions (IFTIs): Reported when funds are sent or received from overseas accounts.

Staff Training & Compliance

All staff members receive regular AML/CTF training to ensure awareness of regulatory obligations and risk indicators. Our compliance team conducts periodic audits and updates policies to align with evolving regulatory standards.

Record Keeping

We retain all AML/CTF-related records, including transaction data and customer identification documents, for at least seven (7) years as required by law.

Internal Controls and Risk Assessment

We maintain a risk-based approach to compliance by conducting regular risk assessments of clients and transactions. Implementing strong internal controls to mitigate financial crime risks, reviewing and updating AML/CTF policies to reflect changes in legislation and emerging threats.