Financial Services Guide
Combined Financial Services Guide and Product Disclosure Statement
Afmoom Trading Pty Ltd ACN 663 026 846 AFSL No. 549100
Date: 5 December 2023
Version: 1
Introduction
This document is comprised of two parts:
- Part A is our financial services guide (FSG), which tells you about the financial services we offer and is designed to help you decide whether to use them; and
- Part B is the product disclosure statement (PDS), which tells you about the Bless Account which is issued by us and is designed to help you make a decision about whether or not to use those services. It includes general information about the Bless Account and its features, benefits and risks and costs.
Part 1: Financial Services Guide (“FSG”)
This FSG is dated 5 December 2023 and is issued by Afmoom Trading Pty Ltd ACN 663 026 846 AFSL No. 549100 (Bless Payments, we, our or us).
Purpose of this Financial Services Guide
This FSG sets out key information about the financial services we may provide to you. It is designed to assist you to make an informed decision about the financial services we provide and contains important information about:
- who we are and how to contact us;
- the financial services we are authorised to provide;
- how we are paid in relation to the financial services we provide; and
- how to make a complaint.
We strongly recommend that you read and understand this FSG before you engage us to provide you with any financial services. Please contact us if you have any questions.
Who we are
We are the issuer of a mobile application (Bless App) that offers users with an easy to use foreign currency exchange and remittance solution via an online account (Bless Account) which has the following features:
- ability to undertake foreign currency conversions on supported currencies; and
- ability to send money to people overseas.
We only act on our own behalf with respect to the financial services we provide.
Documents you may receive
We may provide you with general financial product advice. General advice is financial advice that does not take your personal needs, objectives or financial situation into account. General advice may be provided to you individually, or as part of broader communications we may distribute through our social media channels or through written collateral such as brochures or other information sheets.
If you open an account with us, you will receive a Product Disclosure Statement (PDS). The PDS contains important information about the Bless Account, including features, benefits, risks, costs, fees and charges. The PDS is intended to help you to make an informed decision about whether to acquire the Bless Account. We encourage you to read it carefully.
The Bless Account is governed by our Terms & Conditions and Privacy Policy, which can be accessed from our website (www.blesspayments.com.au).
Financial services we are authorised to provide
We hold an Australian Financial Services Licence (AFSL No. 549100) and are authorised to provide the following financial services to retail and wholesale clients:
- provide general financial product advice in relation to non-cash payment products and foreign exchange contracts;
- deal in a financial product by issuing non-cash payment products and foreign exchange contracts;
- make a market in foreign exchange contracts.
General advice warning
We only provide factual information or general advice about our services, which does not take your personal circumstances into account. As a result, before acting on any information or advice we provide, you should consider the appropriateness of it having regard to your personal objectives, financial situation and needs. You should carefully consider the PDS of a financial product before making a decision about whether to acquire it.
How we are paid for our services
Any general financial product advice we provide is free of charge.
We will charge you a fee for converting funds from one currency to another and sending money overseas. We may charge a percentage based fee or fixed fee for undertaking these activities on your behalf. Our current fee rates are available on the Bless App or you can contact us to request this information without charge. Our fees are updated from time to time.
Bless Payments may introduce new fees and charges or increase its existing fees and charges at any time by giving notice via the website or Bless Account.
How to give us instructions
If you wish to use our services, you may give us your instructions via your Bless Account.
Disclosure of any conflicts of interest
We do not have any relationships or associations which might influence us in providing you with our financial products and services.
Compensation arrangements in place
Bless Payments maintains professional indemnity insurance to cover its advice and any recommendations provided. This policy complies with the requirements imposed under the Corporations Act 2001 (Cth).
Contact
If you have any further questions about the financial products and services we provide, please contact us:
Email: hello@blesspayents.com.au
Address: PO Box 7225 Cloisters Square PO WA 6850
Website: www.blesspayments.com.au
Complaints
If you have a complaint or concern about the products and services provided to you, we encourage you to contact us about your concern. When your complaint is received by us it will be investigated. If your concern is not resolved, or if you are not satisfied with the decision you may contact the Australian Financial Complaints Authority (AFCA), which is an external dispute resolution scheme. AFCA’s details are:
Phone: 1800 931 678
Email: info@afca.org.au
Address: GPO Box 3, Melbourne VIC 3001
Website: www.afca.org.au
Part 2: Product Disclosure Statement (“PDS")
This PDS is dated 5 December 2023 and is issued by Afmoom Trading Pty Ltd ACN 663 026 846 AFSL No. 549100 (Bless Payments, we, our or us).
We are the issuer of the non-cash payment and foreign exchange products described in this PDS.
This PDS explains what you need to know about the products that we can offer you. It is designed to:
- provide you with the information you need to determine whether the products we offer are appropriate for you; and
- explain the terms and conditions, rights and obligations associated with our products.
When you open an account with us (Bless Account), you will be provided with a separate document titled “Terms and Conditions”. It contains terms and conditions that govern the Bless Account. You can obtain a free copy of the Terms and Conditions on our website (www.blesspayments.com.au).
Important Information
We hold an AFSL (AFSL No. 549100) and are the issuer of the non-cash payment product and foreign exchange contract product.
This PDS does not take into account your financial situation, personal objectives or needs. Before acting on the information in this PDS, you should read this PDS carefully, and then consider it in light of your objectives, financial situation and needs. If in doubt, we recommend that you seek independent financial advice to ensure that a particular product is suited to your financial situation and requirements.
This PDS is only issued in Australia and does not constitute an offer in any other jurisdiction where it would be illegal to make such offers or where such offers are not permitted.
The information in this PDS is up to date at the time of preparation but may change from time to time. A change to this information which is not materially adverse may be communicated by making the updated PDS available on our website (www.blesspayments.com.au). You can also obtain an electronic copy of any updated PDS (without charge) on request.
Where this PDS includes a reference to content on our website, the relevant content of the website referred to forms part of this PDS. If you cannot find that information on our website, you can contact us and ask for a copy of the statement or information without charge.
Examples we use in this PDS are only for illustration and are included to help you understand our products. They are not exhaustive.
Should you have any queries about this PDS, please contact us. Our contact details are at the start of this PDS.
Who we are, and what we are authorised to do?
We hold an AFSL (AFSL No. 549100) and are the issuer of the non-cash payment and foreign exchange products described in this PDS.
We will only provide you with factual information or general advice in relation to our products, which does not consider your personal objectives, financial situation or needs.
Before acquiring the products referred to in this PDS you should read this PDS carefully, and then consider your objectives, financial situation and needs and take all reasonable steps to fully understand the products we are offering. We recommend that you seek independent financial advice to ensure that a particular product is suited to your financial situation and requirements.
Opening a Bless Account
Step 1: Read this PDS
Step 2: Download the Bless App
Step 3: Read and accept the Terms and Conditions contained on the Bless App by
ticking the box.
Step 4: Set up a Bless Account
Non-Cash Payment Product
A non-cash payment is made when a person makes a payment or causes a payment to be made otherwise than by the physical delivery of cash.
The Bless App provides an easy-to-use system to convert foreign currency and make payments to overseas jurisdictions via their Bless Account.
By logging into your Bless Account you can conveniently and securely access the following services:
- convert funds from AUD to another currency; and
- make payments to a third party bank account held with an overseas bank.
You can access your Bless Account via the Bless App. To log-in to your Bless Account you must enter your account login and password. You must keep your account login and password secure at all times.
We may earn and retain interest on funds held in your Bless Account.
The Bless Account includes a foreign currency exchange service, which allows you to convert AUD held in your Bless Account to another Supported Currency as part of making a payment or transfer to an overseas recipient.
The foreign exchange contract terms (which includes the exchange rate) are locked once you have accepted the terms of the relevant conversion, and the conversion is undertaken once funds required to undertake the conversion are deposited in your Bless Account. Despite accepting the foreign exchange terms, we may refuse to enter into, or cancel, any foreign currency conversion at our absolute discretion.
You can make payments in AUD or another Supported Currency from your Bless Account. Bless may place limits on the amount of funds that you can receive, hold, transfer and withdraw from your Bless Account. Any such limits can be viewed on Bless’ website (www.blesspayments.com.au).
You can transfer AUD into your Bless Account from a bank account that you hold with an ADI by following the instructions on the Bless App. We may allow you to receive or load funds into your Bless Account in different ways.
You can transfer the funds held in your Bless Account to an overseas bank account by following the instructions on the Bless App.
You are also able to review and check your Bless Account balance 24 hours a day, 7 days a week, and view your Bless Account transaction history.
The list of Supported Currencies is available on our website and subject to change from time to time.
Foreign Exchange Contracts
A foreign exchange contract is a transaction where one currency is sold and another currency is purchased at an agreed exchange rate.
In order to send money to overseas recipients, you are required to convert AUD into the relevant destination currency. A foreign exchange conversion is undertaken pursuant to foreign exchange contracts where you and us agree to exchange one currency for another currency at an agreed exchange rate. The conversion is undertaken immediately after the amount to be exchanged (plus our fees) have been deposited and cleared in your Bless Account. A new foreign exchange contract will be entered into for each foreign exchange conversion that you do with us.
FX trades are over-the-counter (OTC). They are entered into between you and us. This means that foreign currencies we are exchanging are not traded on a licensed financial market (such as a stock exchange).
Bless provides you with the ability to enter into foreign exchange contracts through the Bless Account.
The Bless Account will provide the following functionality:
- Quotes on foreign currency exchange trades. This is the foreign currency exchange rate, which is the price at which we are willing to convert AUD to another Supported Currency.
- The value of the foreign currency exchange trade. This is both the amount of AUD required to be deposited to your Bless Account and the value of Supported Currency held once the FX trade has been completed.
- The time period in which you must deposit AUD to your Bless Account in order to complete the trade. Once you have agreed to the foreign exchange terms in the Bless App, this will lock in the foreign exchange contract for a period of time (deposit deadline) and require that you deposit the required funds to your Bless Account before the deposit deadline.
- Fees applicable to the foreign currency exchange trade.
As long as we hold or receive sufficient cleared money from you in your Bless Account before the deposit deadline, we will settle the foreign currency trade. Settlement is near-immediate. However, if we do not receive money from you before the deposit deadline, the foreign currency exchange contract will automatically cancel and you will be required to enter into a new trade with us.
We are not a speculative trading platform. You must not use the Bless Account for currency trading or related purposes.
Different service providers offer different exchange rates. Bless cannot guarantee the best rate available on the market, but endeavours to provide rates that are competitive.
Client Monies
The Bless Account is an electronic payment facility. The funds shown in your Bless Account will be held in an account with an ADI until you transfer your funds to another person. Your funds are segregated from our money and held in a pooled account which is held by an ADI that is licensed by the Australian Prudential Regulatory Authority (APRA) to carry on a banking business.
You have no right to any interest on funds held in your Bless Account. Individual Bless Accounts are not separated from each other but are pooled together. The money is held on trust for you until you transfer or withdraw the money or otherwise provide us with a legal right to that money because of outstanding fees owed to us or in such other circumstances as referred to in the Terms and Conditions.
Significant Benefits of Products
Access to Bless Account at any time
You can access your Bless Account and our services 24 hours a day, 7 days a week.
Access to transaction history
You are able to access your complete Bless Account transaction history at all times.
Currency exchange
You are able to convert AUD to another Supported Currency for the purposes of making a payment or transfer of funds to an overseas recipient from your Account. The currency exchange occurs immediately once you have accepted the foreign exchange conversion terms proposed by Bless and deposited the relevant funds to your Bless Account.
Send money overseas
You are able to send money to recipients in over 15 countries. The list of overseas countries will be published on our website.
Significant Risks of Products
Incorrect beneficiary or other payment detail errors
You are responsible for ensuring the bank details of a third-party recipient are populated accurately when making a payment. You are responsible for any errors or mistakes made while transacting on your Bless Account. If you make an error or mistake, we may not be able to recover the funds and will not be liable in these circumstances.
Unauthorised transactions
There is a risk that your Bless Account may become compromised and we receive an instruction that appears to be from you, but is not. You will be responsible for losses arising from any unauthorised transactions on your Bless Account. We will assume that all instructions we receive from your Bless Account have been authorised by you. You must notify us immediately if you suspect that your Bless Account has been compromised or subject to unauthorised transactions.
Correspondent banks
When making a payment overseas, it is not always possible to know how much a customer will be charged by the banks involved in the transaction. This means the amount you have converted to send to an overseas recipient may not necessarily be the amount the recipient actually receives.
Payment reversals
We may, without notice, reverse a transaction or remove funds from your Bless Account in certain circumstances, including where fraud is suspected or where we reasonably believe that there is a risk associated with the transaction or your Bless Account.
Delay or loss of funds
We rely on other counter-parties and banking partners to transfer funds to your intended destination overseas. There is a risk that your funds may be disrupted, delayed or lost if our counter-parties and banking partners become insolvent or are otherwise subject to a force majeure event. Any such disruption, delay or loss is beyond our control and we will not be liable for any loss you incur.
Operational risk
The Bless App is intended to be operational 24 hours a day, seven days a week. However, access to the Bless App may be interrupted by scheduled or unscheduled maintenance or from inadequate or failed technological systems, internal processes or external events.
There are also certain risks associated with processing your transactions/instructions and communicating through the internet. These risks include software errors and bugs, problems with internet access and data transfers, interrupted service, security breaches and other faults.
This means that you may be unable to use the Bless App when you wish and you may suffer a loss.
AML/CTF risk
We have obligations under the AML/CTF Laws. One of these obligations is to screen clients and transactions for risks of money laundering, terrorist financing and other criminal activity. There is a risk that a transaction may be delayed or cancelled due to the processes or systems we have in place for these screening purposes. Our banking and other partners also use similar processes which may also delay or cancel a transaction without notice. Neither we, nor our banking and other partners, are required to tell you the reasons for the delay or cancellation if there is a suspicion of money laundering, terrorism financing or other criminal activity.
Account suspension and/or termination
We may hold, suspend or cancel your Bless Account in certain circumstances including where fraud is suspected, where we reasonably believe there is a risk associated with your Bless Account or where you have breached our Terms and Conditions.
Use and access to the Bless App
You are responsible for providing and maintaining the means by which you access the Bless App. If you do not have access to a smartphone or internet, you will be unable to access the Bless App. This means you will be unable to transact on the Bless App during this time, which may cause you to suffer a loss or other inconvenience.
Discretionary powers
Under the Terms and Conditions, we have a number of discretionary powers which may affect you. You should ensure that you understand these discretionary powers by reading the Terms and Conditions.
No cooling off
There are no cooling off rights in relation to the Bless Account.
Counterparty risk
Counterparty risk is the risk that another party may default on their contractual obligations. You have a counterparty risk with us as you are reliant on us to meet our obligations to you under the Terms and Conditions. We are also reliant on agreements that we have entered into with third party service providers and the actions of these third parties may impact on our ability to fulfil our obligations to you.
If our business becomes insolvent, you will become an unsecured creditor to the extent that you have money in your Bless Account. The extent to which you may recover these funds will be determined by applicable insolvency laws.
Exchange rate risk
Foreign currency exchange rates are subject to fluctuations all the time. If you exchange currency as part of making a payment or transfer, you and the ultimate recipient of those funds will be subject to fluctuations in the value of that currency. It is possible that the exchange rate improves after we have exchanged your currency or after you have agreed to the relevant foreign currency exchange terms. If funds are reversed and paid to the Bless Account in a currency other than AUD, then you may suffer loss resulting from any movements in the currencies before funds can be converted to AUD and settled to your Bless Account.
Non-supported payments
There is a risk that you may make a payment in a foreign currency to an account which does not accept or otherwise accommodate that particular currency. In these circumstances, the beneficiary bank may convert the foreign currency to another currency which is compatible with the beneficiary bank account. Fees and charges, including foreign currency conversion charges, may apply in those circumstances and may result in the recipient receiving less funds than you anticipated.
No application of Financial Claims Scheme
The Bless Account is not a bank account and does not have the benefit of the Financial Claims Scheme.
Fees and charges
We may charge you a fee for providing you with the Bless Account and its corresponding financial products. Our fees are published on our website www.blesspayments.com.au. Our fees are updated from time to time.
We may introduce new fees and charges or increase its existing fees and charges at any time by giving you notice via our website and/or Bless App.
How we are paid
Our directors and employees are remunerated by salary.
They may also be eligible for a discretionary bonus based on their performance, which is based on both financial and non-financial criteria. Employees may also be rewarded by monetary and non-monetary benefits. It is not possible to determine in advance what (if any) additional benefits an employee will receive as these benefits are not generally attributed to any particular product or service they provide.
You may request more details about the way these people or entities are remunerated within a reasonable time after receiving this PDS and before any financial services are given to you.
We do not have relationships or associations which might influence us in providing you with our financial products and services.
Stopping or cancelling a payment
Once a funds transfer has been processed from your Bless Account, it will be extremely difficult for us to recall it. An attempt to recall the funds may be subject to further fees charged by the banks/service providers involved. Those charges will be passed on to you and are outside of our control. We will also pass on to you any costs we incur (including foreign exchange costs) in arranging the recall. We will also charge you an administration fee for assisting with the recall.
If you believe that you have instructed us to make a funds transfer in error or that an unauthorised transaction has occurred, you must notify us immediately.
We are not obliged to enter into any transactions you instruct us to execute under your Bless Account. We are entitled to delay, suspend, refuse to enter into or cancel any transactions in our absolute discretion without being liable for such action. We may also reverse a payment transaction in certain circumstances, including where we reasonably suspect it involves fraud or other suspicious or illegal activities.
Terms & Conditions
The Terms and Conditions are set out on our website. You must agree to the Terms and Conditions before opening your Bless Account.
The Bless Account is provided on an execution-only basis. You are responsible for any instructions you provide to us. We are not required to inquire as to the validity of instructions received from your Bless Account, including whether the person providing the instructions is actually authorised to do so.
A foreign exchange contract or payment transaction cannot be cancelled once entered into. You are also responsible for ensuring payment transaction details are populated correctly and that there are no errors or mistakes in populating those details. Inaccurate details may result in the transfer of funds not reaching their intended recipient. We will not be liable in these circumstances.
The Bless Account is provided ‘as-is’ without any express or implied warranties, except for those which cannot be excluded by contract.
We will not be responsible:
- for failing to accept any transaction or instruction;
- for any loss you incur from any delay in the transmission or wrongful interception of instructions;
- for any loss you incur as a result of us not receiving any instructions from you, whether as a result of any failure or delay of the Bless Account or otherwise; or
- where we suspend, refuse to enter into or cancel any transaction or instruction.
You agree to indemnify us for any loss we incur:
- for any error you make in providing instructions to us;
- for any payment reversal or removal of funds from your Bless Account; or
- in relation to any recall request.
We will limit our liability to you such that it will not exceed:
- $25,000, where the claim is caused by our fraud, negligence or wilful misconduct; or
- otherwise, the fees paid to us by you in the preceding 12-month period.
We can unilaterally vary the Terms and Conditions by providing you with at least 30 days’ notice of the variation. Either party can terminate the Terms and Conditions at any time by providing notice to the other.
You agree to hold and transact on the Bless Account as principal and not as an agent on behalf of another party.
You agree to provide various warranties, including that you will not enter into transactions for trading or speculative purposes.
The above is a summary of some of the key clauses in the Terms and Conditions. We strongly suggest you read and understand the full Terms and Conditions, which can be accessed at www.blesspayments.com.au.
Instructions
If you wish to use your Bless Account, you can only give us your instructions via the Bless App. We will not take your instructions via any other method.
Tax Implications
There may be tax implications for you in relation to the Bless Account and any transactions you enter into.
Taxation laws are very complex and vary depending on your personal circumstances. You should discuss any taxation questions you may have with your tax adviser before using our products or services.
Our Role
Bless is the product issuer of the non-cash payment and foreign exchange contract products described in this PDS. We act on our own behalf in issuing these products to you.
We are also the service provider. Our employees can give you general advice and help you use our products and services.
Complaints
For information on our dispute resolution process and how you can make a complaint, please refer to the “Complaints” section in Part 1 (FSG).
Contact
For our contact details, please refer to the “Contact” section in Part 1 (FSG).
Privacy
The privacy of your information is important to us. We have practices which include the secure storage of personal information and safeguards against the accidental release of personal information.
You will be required to provide us with certain information to enable us to comply with our obligations under the AML/CTF Laws.
We handle all information provided to us in accordance with our Privacy Policy. You can obtain a copy of our Privacy Policy on our website.
ESG
We do not take labour standards or environmental, social or ethical considerations into account when offering the Bless Account and its respective financial products.
Definitions
AML/CTF Laws means the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).
Bless Account means the digital wallet that we provide to you which enables you to enter into foreign exchange contracts and make payments to recipients overseas.
Supported Currency means each currency approved by us from time to time that can be used to make a payment from the Bless Account, as updated on our website from time to time.
Terms and Conditions refers to the terms and conditions that govern the Bless Account which are available on our website (www.blesspayments.com.au). They are incorporated by reference into the PDS.
