Frequently Asked Questions


Koi Pay is regulated by AUSTRAC (Australian Transaction Reports and Analysis Centre) and operate in compliance with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act), and the Anti-Money Laundering and Counter-Terrorism Financing Rules (AML/CTF Rules). We fulfil all of our obligations as a provider of a designated service.

We are not a deposit taker as our technology allows us to process within a through period meaning we are not considered a deposit taker. We do not allow users to make deposits into their account

We do not have a financial services licence and do not require one under our current model because we are not a deposit taker. We are also covered by our card issuers who have financial services licences.

Koi Pay manages the AML/CTF risk via a comprehensive customer KYC (Know Your Customer) on boarding process and an advanced transaction monitoring system. We only issue cards to Chinese students with valid students Visas. Our AML/CTF risk is classified as low.


There are 150,000 Chinese students in Australia. Collectively they spend $2.3 billion each year.

Koi Pay has identified that the Coronavirus will not affect our trajectory in the long-term. Koi Pay will not launch prior to semester 2 of 2020 and if anything, the influx of students when the borders are re-opened will enhance our marketing strategy. We are well poised to be patient and wait for the situation to improve.


We developed a proprietary technology that allows us to connect any alternative payment system with the EFTPOS network. We can issue cards that directly link with an alternative payments wallet and it can be spent at any merchant on the EFTPOS rails. We handle all the tricky stuff on the back end and make it seamless for the user.

Chinese currency transfer is regulated by Chinese law. Each individual cannot transfer more than 50,000 USD out of China each year. As a result of this companies like TransferWise do not operate out of China. Wire transferring money from China to Australia incurs high fees which some students are circumventing by flying suitcases of cash from China or by laundering through student conversion group chats. As well as being expensive wire transfers also take time, in some cases up to 36 hours. Our offering provides a neat solution to all of these problems.

The great thing about accelerating our venture through the University of Queensland is that we do not need to get out of the building to speak to Chinese students. They are literally in the building. We have built an extensive network of Chinese students and we spent months speaking to them and validating the problem and testing our hypothesis while we were developing the technology. From bubble tea vouchers to QR code posters we imbedded ourselves in the Chinese community at the University.

The balanced and diverse skill set of our team is reflected in our novel approach to this problem. We are not Chinese, and we don’t pretend to be. We think transparency is important and we pride ourselves on being an Australian company. Our founders spent months working in China and building an understanding of how different the culture is. We know we need to bring Chinese input into everything we do. Our real value is in our payment expertise mixed with the University and Chinese networks. We are accelerated by the University of Queensland Ventures and this has given us a unique perspective and access to the problem.

We solve Chinese payments for Chinese students. Once we have achieved this we move on to solving Chinese payments for the world. There are over 600,000 Chinese international students and this number is growing. Once we solve this problem we will move onto Chinese expatriates. Koi Pay is a locally minded service with global ambitions.

Our priority at the moment is focused on solving this problem. What we have developed can be applied to a multitude of other use cases from Cryptocurrency to Frequent flyer miles, we can connect any alterative payment system with the EFTPOS network.