Further to my response to a comment stating that this does not fall foul of AUSTRAC's requirements, I think it does break the law with respect to the Corporations Act's requirements for an Australian Financial Services License (AFSL)...

http://www.asic.gov.au/asic/ASIC.NSF/byHeadline/Licensing

"An Australian financial services (AFS) licence authorises licensees to:

1 provide financial product advice to clients;

2 deal in a financial product;

3 make a market for a financial product;

4 operate a registered scheme;

5 PROVIDE A CUSTODIAL OR DEPOSITORY SERVICE;

6 provide traditional trustee company services."

I think you are performing #5 above, therefore are breaking the law by operating without an AFSL (if you do have an AFSL, the license number should be displayed on your website).

Plus consider the Electronic Funds Transfer Code of Conduct...

http://www.asic.gov.au/asic/asic.nsf/byheadline/Electronic+F...

Not trying to rain on your parade, just making sure you are aware of the relevant laws you (may) be breaking!