Evidence records

documentedAIRWALLEX PTY LTD is an Australian private company with Australian Company Number (ACN) 609 653 312 and Australian Business Number (ABN) 37 609 653 312. The Australian Business Register records the ABN as active and the company name as unchanged since 3 December 2015, and its registration for goods and services tax from 7 December 2015. ¹

documentedThe register gives the company's main business location as Victorian postcode 3146 from 3 December 2015 and postcode 3000 from 22 March 2019. AUSTRAC's notice of January 2026 was addressed to Airwallex Pty Ltd at Level 7, 15 William Street, Melbourne VIC 3000. ^{1 2}

documentedAirwallex Pty Ltd's modern slavery statement for the year ended 31 December 2025, approved by its board of directors, says the company was founded in late 2015 as a proprietary company in Melbourne and operates as part of the "Airwallex Group", which it defines as Airwallex (Cayman) Limited and its affiliates: a financial technology group headquartered in Singapore with more than 2,400 employees. ³

documentedASIC's register of Australian financial services licensees, published as an open dataset, lists exactly two Airwallex licences: AFSL 487221, held by AIRWALLEX PTY LTD since 5 September 2016, and AFSL 549026, held by AIRWALLEX CAPITAL PTY LTD since 26 April 2024, both with Melbourne VIC 3000 addresses. Airwallex Pty Ltd's licence covers general advice on, dealing in and issuing non-cash payment products and foreign exchange contracts, and making a market in foreign exchange contracts, for retail and wholesale clients. ⁴

documentedAccording to the group's licensing disclosure, Airwallex Pty Ltd, Airwallex SVF Pty Ltd and Airwallex Capital Pty Ltd are registered with AUSTRAC and form one Designated Business Group, and Airwallex SVF Pty Ltd is a corporate authorised representative (CAR number 001313604) under Airwallex Pty Ltd's licence. ⁵

documentedAIRWALLEX PTY LTD is registered under its ABN as a supplier on buy.nsw, the New South Wales government procurement platform, where its profile, updated on 29 April 2024, lists financial services. ⁶

documentedThe Australian Business Register lists seven active entities under the name Airwallex, all in Victorian postcode 3000: AIRWALLEX PTY LTD, AIRWALLEX CAPITAL PTY LTD (ABN 12 661 618 819), AIRWALLEX SVF PTY LTD (ABN 72 672 923 438), AIRWALLEX COMMERCELINK (AUSTRALIA) PTY LTD (ABN 58 698 804 901), AIRWALLEX DIGITAL (AUSTRALIA) PTY LTD (ABN 83 684 938 298), AIRWALLEX HOLDINGS (AUSTRALIA) PTY LTD (ABN 80 696 551 185) and The Trustee for Airwallex Yield Liquidity Fund (ABN 85 306 152 305). ⁸

qualification

The register lists names, numbers and locations only; it does not record shareholders or how these companies are related to one another.

documentedAIRWALLEX HOLDINGS (AUSTRALIA) PTY LTD is an Australian private company with ACN 696 551 185. Its ABN has been active since 28 May 2026; it is not registered for goods and services tax and its main business location is Victorian postcode 3000. ⁹

qualification

The register does not show who owns the company or whether it holds shares in Airwallex Pty Ltd.

documentedAirwallex Capital Pty Ltd (ACN 661 618 819) holds AFSL 549026. The product disclosure statement for the USD unit class of the Airwallex Yield Liquidity Fund (ARSN 678 845 657), dated 4 August 2025, says the fund's responsible entity, K2 Asset Management Ltd (ABN 95 085 445 094), appointed Airwallex Capital as the fund's investment manager, describes it as a related party of Airwallex Pty Ltd, and states that both companies are wholly owned subsidiaries of Airwallex (Cayman) Limited (Registration No. 307718). ¹⁰

documentedThe group's customer-funds page says that in Australia Airwallex SVF arranges for the entire amount of customers' wallet funds to be guaranteed by Australian authorised deposit-taking institutions, as required by the Reserve Bank of Australia, and that, as manager of the Airwallex Yield Liquidity Fund, Airwallex Capital invests customer funds in low-risk assets through its partner J.P. Morgan. ¹¹

qualification

The page does not name the deposit-taking institutions that give the guarantee.

documentedAirwallex (Cayman) Limited is a company incorporated in the Cayman Islands under registration number 307718. A certified shareholder report filed with the SEC by Robinhood Ventures Fund I for the period to 31 March 2026 notes that this portfolio company is incorporated in the Cayman Islands and has operations in Singapore and the United States. ^{12 10}

documentedAirwallex (New Zealand) Limited (company number 8151714, NZBN 9429048910057) was registered on 12 January 2021. A copy of the New Zealand companies register shows all 6,000,001 of its shares held by Airwallex (Cayman) Limited (307718), which is also recorded as its ultimate holding company, and its registered office at 16 Kingston Street, Auckland. ¹⁴

qualification

The copy was retrieved from a commercial site that reproduces the Companies Office register.

documentedPress accounts describe the group's headquarters moving from Melbourne to Hong Kong in 2018 and from there to Singapore in 2023; in December 2025 the group named San Francisco as a second global headquarters alongside Singapore. In 2017 the start-up had about 40 staff and offices in Melbourne, Shanghai and Hong Kong, was opening in London and planned a presence in Singapore. ^{15 16 17 13 18}

qualification

The dates of the moves come from press reports; an Australian newspaper in 2026 describes the group as officially domiciled in the Cayman Islands.

documentedIn its announcement of the Australian board appointments the group described itself as founded in Melbourne in 2015, holding more than 80 licences across North America, Europe, the Middle East and Asia-Pacific, co-headquartered in San Francisco and Singapore, with more than 2,200 employees in 26 offices. ^{19 3}

qualification

These figures are the company's own description; Airwallex Pty Ltd's modern slavery statement for 2025 gives more than 2,400 employees.

documentedAccording to a US business magazine, co-founder Lucy Liu provided Airwallex's initial US$1 million of seed funding in 2015, after which the start-up raised a further US$3 million from small venture firms. Another business magazine, in a corrected account of 2026, reports that Liu offered US$2 million and that Jack Zhang accepted US$1 million. ^{1 2}

qualification

Both accounts come from interviews; no filing records the seed investment or the shares it bought.

documentedOn 5 July 2016 Airwallex announced a US$3 million pre-Series A round led by the Shanghai-based venture firm Gobi Partners, with Gravity VC and the angel investors Huashan Capital One taking part. ³

documentedA technology news site reported on 1 May 2017 that the Melbourne-based start-up had closed a US$13 million Series A round led by Tencent, its first investment in an Australian start-up, with Sequoia China, MasterCard and the existing investor Gobi Ventures taking part; the start-up had raised US$3 million the previous summer. ⁴

qualification

A press report of the round; the start-up's own announcement is not among the retained records, and the issuing company is not named.

documentedA Singapore business newspaper reported on 3 July 2018 that Airwallex had raised US$80 million in a Series B round led by its Series A investors Tencent and Sequoia China, with Hillhouse, Horizons Ventures, Central Capital Ventura and Square Peg joining; Square Peg had also taken part in a US$6 million Series A+ round in December 2017, and total funding reached US$102 million. ⁵

qualification

Based on the company's statement as reported by the newspaper; the issuing company and the investors' stakes are not stated.

documentedA technology news site reported on 25 March 2019 that Airwallex had closed a US$100 million Series C round valuing it above US$1 billion, led by DST Global with returning investors Sequoia China, Tencent, Hillhouse Capital, Gobi Partners, Horizons Ventures and Square Peg, bringing total funding above US$200 million. ⁶

qualification

Reported from the company's announcement, in which it disclosed a valuation for the first time; stakes are not stated.

documentedA technology news site reported on 15 April 2020 that Airwallex had raised a US$160 million Series D round, including ANZi Ventures, the investment arm of ANZ Bank, and Salesforce Ventures, along with returning investors DST Global, Tencent, Sequoia Capital China, Hillhouse Capital and Horizons Ventures, bringing total funding to US$360 million. The round was extended in March 2021. ^{7 8}

qualification

Reported from the company's announcement; the March 2021 extension is mentioned by a later report without its size or investors.

documentedIn September 2021 Airwallex raised US$200 million in a Series E round at a US$4 billion valuation, led by Lone Pine Capital, with new investors G Squared and Vetamer Capital and existing investors 1835i Ventures (formerly ANZi), DST Global, Salesforce Ventures and Sequoia Capital China. In November 2021 Lone Pine Capital led a further US$100 million (Series E1), with 1835i Ventures and Sequoia Capital China, at a US$5.5 billion valuation; total funding then stood at US$802 million. ^{8 9}

qualification

Two trade reports of the company's announcements; no investor's stake is stated.

documentedA news agency reported on 11 October 2022 that Airwallex had raised US$100 million in an extension of its Series E round at an unchanged US$5.5 billion valuation, from existing investors including Tencent Holdings, Sequoia Capital China and Lone Pine Capital, joined by the Australian superannuation fund HostPlus and a North American pension fund; the company said total funding exceeded US$900 million. ¹⁰

qualification

The agency relays the company's statement; the North American pension fund is not named.

documentedOn 21 May 2025 Airwallex announced a US$300 million Series F round at a US$6.2 billion valuation, including US$150 million of secondary share transfers, with Square Peg, DST Global, Lone Pine Capital, Blackbird, Airtree, Salesforce Ventures and several Australian pension funds, and Visa Ventures joining as a strategic investor; it put total funding above US$1.2 billion. ¹¹

documentedAirwallex announced on 8 December 2025 that it had raised US$330 million in a Series G round valuing it at US$8 billion, led by Addition with T. Rowe Price, Activant, Lingotto, Robinhood Ventures and TIAA Ventures. ¹²

documentedRobinhood Ventures Fund I's certified shareholder report filed with the SEC lists, as of 31 March 2026, 1,173,709 shares of Series G preferred stock of Airwallex (Cayman) Limited, acquired on 21 November 2025, at a cost and fair value of US$25,000,002. ¹³

documentedIn June 2026 Airwallex announced US$320 million of Series H funding at an US$11 billion valuation, led by the returning investor Addition, with Baillie Gifford, Hummingbird, QED Investors, T. Rowe Price, Hedosophia, Haun Ventures, Washington University in St. Louis and Amex Ventures. ^{1 12}

documentedA personal-finance magazine reported in January 2026 that over ten years Airwallex had held seven funding rounds and raised more than US$1.5 billion of venture capital, including from the Australian firms AirTree, Blackbird and Square Peg. ¹⁴

qualification

Round counts differ between accounts depending on how extensions are counted; the rounds above are those named in the retained reports.

documentedA venture-capital database profile of Airwallex (Cayman) Limited also lists Greenoaks Capital Partners, Grok Ventures and Skip Capital as Series D investors and Hermitage Capital as a Series E investor, without stakes or dates. An Australian financial newspaper wrote in 2023 that Grok Ventures, the investment company of Atlassian co-founder Mike Cannon-Brookes, had invested. ^{15 16}

qualification

These investors are named only by an aggregator and the newspaper; no announcement in the retained records names them.

documentedOn 28 July 2021 Airwallex announced Capital 49, a venture capital fund set up by Airwallex's founders in cooperation with the company, aiming to raise US$200 million from the founders and other investors for companies in Airwallex's ecosystem; Jack Zhang was named its founder, and the fund had made two fintech investments. ²²

qualification

The announcement does not identify the fund's legal entity or jurisdiction.

documentedThe group's licensing disclosure lists the licensed companies by country: Airwallex Pty Ltd and Airwallex Capital Pty Ltd in Australia, AWX Brasil Instituição de Pagamento in Brazil, Airwallex (Canada) International Payments in Canada, Yunhui Pay in mainland China, Airwallex (Hong Kong), UniCard Solution and Airwallex Capital Hong Kong in Hong Kong, PT Skye Sab Indonesia, Airwallex (Israel), Airwallex Japan, AWX Lithuania, Airwallex (Malaysia), MexPago in Mexico, Airwallex (Netherlands) and Airwallex Capital (Netherlands), Airwallex (New Zealand), Airwallex (Singapore) and Airwallex Capital (Singapore), Paynuri in South Korea, Airwallex (UK), Airwallex US and AWX Capital US in the United States, and a Vietnamese member company holding an intermediary payment service licence. ¹

qualification

This is the group's own list; regulator records retained in the case confirm the entries for Australia, the Netherlands, Lithuania, Singapore, Hong Kong (UniCard and Airwallex Capital Hong Kong), Japan, Malaysia, the United Kingdom and Brazil.

documentedDe Nederlandsche Bank's public register lists Airwallex (Netherlands) B.V. (Chamber of Commerce 77519256, LEI 724500FH0D6K3YH7TS78, seat Amsterdam) as an electronic money institution under relation number R179622, authorised since 30 April 2021 to issue e-money and provide payment services, with an EU passport. Airwallex Netherlands Stichting is related to it as the third-party account entity holding customer funds and is included in DNB's supervision. ^{2 1}

documentedAccording to the licensing disclosure, Airwallex Capital (Netherlands) B.V. has been licensed by the Dutch Authority for the Financial Markets (AFM) since 31 July 2025 to receive, transmit and execute orders for participation rights in recognised money market funds, with a passport across the European Economic Area. ¹

qualification

The AFM register entry itself is not among the retained records.

documentedThe Bank of Lithuania's register lists AWX Lithuania, UAB (company code 305697289, authorisation code LB002102, Vilnius) as an electronic money institution with a licence for unlimited activity valid from 6 October 2021, and as a currency exchange operator. ^{3 1}

documentedThe Monetary Authority of Singapore's Financial Institutions Directory lists AIRWALLEX (SINGAPORE) PTE. LTD. as a major payment institution licensed for account issuance, domestic and cross-border money transfer, merchant acquisition and e-money issuance, with Wu Kai named as key personnel. The licensing disclosure gives licence number PS20200541 and names Airwallex Capital (Singapore) Pte. Ltd. as holder of capital markets services licence CMS101830. ^{4 1}

documentedIn Hong Kong, the licensing disclosure lists Airwallex (Hong Kong) Ltd as a money service operator licensed by the Customs and Excise Department (licence 16-09-01929). The Hong Kong Monetary Authority's register lists UniCard Solution Limited as a stored value facility licensee under licence SVF0009 since 4 November 2016, and the Securities and Futures Commission's register shows Airwallex Capital Hong Kong Limited (CE number BUL570) licensed since 2 September 2024 for advising on securities and asset management, with no licence for virtual-asset services. ^{1 5 6}

documentedJapan's Financial Services Agency registers list Airwallex Japan K.K. (corporate number 1010401137711, Minato-ku, Tokyo) as an electronic payment agency service provider registered by the Kanto Local Finance Bureau as No. 119 on 4 September 2023 and as a second-type funds transfer service provider No. 00100 from 8 September 2025. The licensing disclosure adds a registration with the Ministry of Economy, Trade and Industry as a credit-card-number handler (No. 175, 14 November 2023). ^{7 8 1}

documentedBank Negara Malaysia's directory lists Airwallex (Malaysia) Sdn. Bhd. (1269761X) as a registered non-bank merchant acquirer and e-money issuer with foreign ownership, whose e-money products are a multi-currency digital wallet and a corporate Visa prepaid card. The licensing disclosure adds a class A money services business licence (No. 00767) for remittance and money changing. ^{9 1}

documentedAirwallex (New Zealand) Ltd is registered on New Zealand's Financial Service Providers Register as FSP1001602, according to the licensing disclosure. ¹

documentedThe licensing disclosure lists Yunhui Pay Co. Ltd as licensed by the People's Bank of China to operate Type I stored value accounts under licence Z2025844000016. ¹

qualification

No Chinese registry or central bank record for Yunhui Pay is among the retained documents, and the disclosure does not state how the company is owned.

documentedA regional technology news site reported on 10 December 2025, citing an Airwallex statement, that the group had acquired majority ownership of PT Skye Sab Indonesia, which holds a category 1 payment service provider (PJP) licence; the licensing disclosure gives the Bank Indonesia licence number 23/583/DKSP/Srt/B. ^{10 1}

qualification

The acquiring group company and the size of the stake are not stated.

documentedA South Korean business newspaper reported on 22 January 2026 that Airwallex had acquired the South Korean company Paynuri, which holds electronic payment gateway and prepaid payment instrument licences and a foreign-exchange business registration; a news agency reported the acquisition of Paynuri Co Ltd the same week. A Korean company database lists the former (주)페이누리 under the name (주)에어월렉스코리아 (Airwallex Korea), founded on 10 October 2014, with its representative given as 카이우, the Korean rendering of the name Kai Wu. ^{11 12 13}

qualification

The buyer within the group is not named, and no Korean regulator record is among the retained documents. The database does not identify its representative further, so the person is not linked here to the group executive of that name.

documentedA technology news site reported on 5 March 2021 that Airwallex had completed its acquisition of the Hong Kong prepaid card operator UniCard Solution after the Hong Kong Monetary Authority consented to Airwallex becoming a shareholder controller. A private-markets database profile records that Airwallex Pty Limited acquired UniCard Solution Limited in March 2021 and lists Mastercard International Incorporated and Airwallex as its current investors. ^{14 15}

qualification

The database is the only retained record naming the Australian company as the buyer; the group's licensing disclosure describes UniCard as a member of the Airwallex group without naming its shareholder.

documentedFlorida's corporate register lists five Airwallex limited liability companies registered as foreign entities: AIRWALLEX US, LLC (M19000010601), AIRWALLEX CAPITAL (US) LLC (M26000004431), AIRWALLEX DIGITAL (US) LLC (M26000004675), AIRWALLEX COMMERCELINK (US) LLC (M26000009336), all active, and AIRWALLEX FINANCING SERVICES (US) LLC (M25000005134). According to the licensing disclosure Airwallex US, LLC is licensed as a money transmitter in the listed US jurisdictions and AWX Capital US is a FINRA member firm. ^{16 1}

qualification

The Florida register shows names, numbers and status only, without members or managers.

documentedAccording to the licensing disclosure, Airwallex (Canada) International Payments Ltd is registered with FINTRAC as a money services business (M19395067), licensed in Québec as a money services business (No. 14460), and has applied to the Bank of Canada for registration as a payment service provider. ^{1 17}

documentedAccording to the licensing disclosure, Airwallex (Israel) Ltd (company number 516851961) is authorised by the Israel Securities Authority to provide payment services. ¹

documentedAirwallex announced the acquisition of Leapfin, a financial data automation platform specialising in revenue recognition and reconciliation, in a press release of 4 June 2026. ¹⁸

documentedA US business magazine reported in June 2026 that Airwallex is incubating Metal, a cryptocurrency start-up led by Loong Wang and Catherine Porter that aims to be a blockchain for tokenised financial products and to help Airwallex process stablecoin payments. ¹⁹

qualification

A magazine account; the corporate relationship between Airwallex and Metal is not described.

documentedAirwallex (UK) Limited (company number 10103420) is an authorised electronic money institution under FCA reference number 900876, with that status from 26 November 2018 according to the FCA's list of e-money firms; it also holds permission to provide e-money and payment services into Gibraltar from the United Kingdom. The same FCA list contains a second entry, 900824, for AIRWALLEX (UK) LIMITED with the status "Cancelled - Authorised EMI". ^{1 2 3 4}

qualification

The FCA list gives no date or reason for the cancelled entry.

documentedXijing Dai, also known as Jacob Dai, is a co-founder of Airwallex. Companies House shows him as a director of AIRWALLEX GLOBAL LIMITED since 10 September 2026, his only UK appointment, at the group's London correspondence address, 45 Mortimer Street. ⁵

documentedCompanies House shows Kai Wu as a director of AIRWALLEX (UK) LIMITED since 16 January 2024 and of AIRWALLEX TREASURY (UK) LIMITED since 5 June 2026, his only UK appointments. ⁶

documentedCompanies House lists Jack Zhang as the only person with significant control of AIRWALLEX (UK) LIMITED (company number 10103420), notified on 6 April 2016, with the nature of control given as "has significant influence or control"; the register shows no corporate owner as a relevant legal entity and no active statements. ⁷

qualification

Significant influence or control is a distinct category from holding shares; the register does not show who holds the company's shares.

documentedJack Zhang was a director of AIRWALLEX (UK) LIMITED from 5 April 2016 until 19 January 2026; that was the only appointment under that officer record. The company's current directors are Paul Gerard Christensen (from 1 October 2026), Pranav Kumar Sood (from 25 August 2026) and Kai Wu (from 16 January 2024). ^{4 8}

documentedCompanies House lists Jack Zhang as the only person with significant control of AIRWALLEX TREASURY (UK) LIMITED (company number 17262855), notified on 5 June 2026, with significant influence or control; Kai Wu and Yueting (Lucy) Liu have been its directors since 5 June 2026. ^{9 6 10}

documentedAIRWALLEX GROUP (UK) LIMITED, company number 17419456, was incorporated in England and Wales on 25 August 2026 as a private company limited by shares with its registered office at 45 Mortimer Street, London, and SIC code 64205 (activities of financial services holding companies). Its first directors were Jack Zhang and Yueting Liu. Its sole subscriber was Jack Zhang, holding its one ordinary share of £1, and the application was filed through Osborne Clarke LLP. ¹¹

documentedCompanies House lists Jack Zhang as the person with significant control of the company, notified on 25 August 2026, holding 75 per cent or more of its shares and voting rights and the right to appoint or remove directors. ¹²

documentedThe company's filing history records Xijing Dai's appointment as a director on 10 September 2026, the end of Yueting Liu's directorship on 3 October 2026, a change of name from AIRWALLEX GROUP (UK) LIMITED to AIRWALLEX GLOBAL LIMITED by resolution of 3 October 2026 (certificate issued on 5 October 2026), and new articles of association filed on 15 October 2026. ^{13 14}

qualification

The filings do not explain the purpose of the company or show any shareholding by Airwallex (Cayman) Limited or Airwallex Pty Ltd.

documentedCompanies House lists AIRWALLEX GROUP (UK) LIMITED (17419456) as the relevant legal entity with significant control of AWX US INVESTMENT HOLDING (UK) LIMITED (company number 17460169), notified on 15 September 2026, owning 75 per cent or more of its shares and voting rights with the right to appoint or remove directors. Its three directors, all appointed on 15 September 2026, are Yueting Liu, Pranav Kumar Sood and Jack Zhang. ^{15 16}

documentedThe Companies House officer record of Yueting Liu lists three appointments, all at 45 Mortimer Street, London: director of AWX US INVESTMENT HOLDING (UK) LIMITED from 15 September 2026, of AIRWALLEX TREASURY (UK) LIMITED from 5 June 2026, and of AIRWALLEX GLOBAL LIMITED from 25 August to 3 October 2026. ¹⁰

qualification

The register does not use the name Lucy; the identity with the co-founder Lucy (Yueting) Liu rests on the Brazilian central bank notice that names her Lucy Yueting Liu and on the matching group roles and address.

documentedOn 15 January 2025 Airwallex announced that it had finalised the acquisition of MexPago, a Mexican payment service provider licensed as an electronic payment funds institution (IFPE), and that MexPago's founder and chief executive Luis Castillejos Ordaz would become Airwallex's country manager for Mexico. The licensing disclosure names the licensee as MexPago Transacciones, S.A.P.I. de C.V., a member of the Airwallex group licensed by Mexico's National Banking and Securities Commission (CNBV). ^{1 2 3}

qualification

A deal database dates the acquisition to 19 October 2023, presumably the agreement; the buyer within the group is not named.

documentedIn the same announcement Airwallex said it had obtained a payment institution licence from the Banco Central do Brasil. The licensing disclosure names the licensee as AWX Brasil Instituição de Pagamento Ltda., authorised as a payment institution (post-paid instruments, payment initiation, e-money issuance and acquiring) and to operate in the foreign exchange market. ^{2 1}

documentedAn Australian business magazine wrote in 2025 that Airwallex had recently acquired MexPago in Mexico and entered Brazil through the acquisition of the payments company UniPay, and that it held more than 60 licences and permits. ⁴

qualification

UniPay is named only in this article; Airwallex's own announcement of its Brazilian licence does not mention it, and no Brazilian record of UniPay is among the retained documents.

documentedIn Comunicado No. 42.107 of 9 September 2024 (case PE 260558) the Banco Central do Brasil published, for objections within fifteen days, that AWX Holding Brasil Ltda. (CNPJ 50.942.433/0001-34) as direct controller and Lucy Yueting Liu as final controller (controladora final) intended to take part in the control of the payment institution AWX Brasil Instituição de Pagamento Ltda. (CNPJ 52.076.716/0001-76, São Paulo). ⁵

qualification

The notice announces an intended controlling interest submitted for authorisation; personal identification details it contains are omitted.

documentedBrazilian federal tax registry data, as reproduced by a commercial aggregator, show AWX HOLDING BRASIL LTDA as an active limited company since 5 June 2023 with share capital of R$36,184,000.00 and holding-company activity (CNAE 6461-1/00) at Avenida Brig Luis Antonio 300 in São Paulo. Its sole partner since 19 July 2023 is YTL AWX LIMITED, a company domiciled abroad, and Cesar Madeira Padovesi has been its administrator since 5 June 2023 and represents the foreign partner. ⁶

documentedThe same registry data record YTL AWX LIMITED as a foreign-domiciled company with Brazilian CNPJ 51.018.106/0001-53, registered on 12 June 2023, with an address at Kingston Chambers, PO Box 173, Road Town, Tortola, in the British Virgin Islands and a holding-company activity code. ⁷

qualification

The registry data do not name the company's owners. The link between YTL AWX LIMITED and Lucy Yueting Liu is that the central bank names her as final controller of the payment institution held through AWX Holding Brasil; no British Virgin Islands record is among the retained documents.

documentedA second Brazilian company, AIRWALLEX (BRASIL) LTDA (CNPJ 49.629.692/0001-20), has been active since 16 February 2023 with share capital of R$1,118,739.00, activity code 6619-3/99 (other auxiliary financial services) and the same São Paulo address, telephone number and e-mail address as AWX Holding Brasil. Its sole partner since 27 March 2025 is AWX INVESTMENT (SINGAPORE) PTE. LTD., represented by Cesar Madeira Padovesi, who has also been its administrator since 16 February 2023. ^{8 9 6}

qualification

Registry data reproduced by a commercial aggregator; the partner before 27 March 2025 is not shown.

documentedSingapore registry data reproduced by a commercial site show AWX INVESTMENT (SINGAPORE) PTE. LTD. (UEN 202312458Z) as a live private company incorporated on 31 March 2023, a holding company with its registered office at 36 Robinson Road, City House, Singapore. ¹⁰

qualification

The page does not show the company's directors or shareholders.

documentedThe same Brazilian registry data list Cesar Madeira Padovesi in 154 companies, mostly as administrator of Brazilian subsidiaries of foreign groups. ⁹

documentedBy Comunicado No. 42.691 of 13 January 2025 the Banco Central do Brasil announced its decision of 8 January 2025 approving Fernando de Vasconcellos Portugal Torres, Maurício Rossini César and Paulo Roberto Ribeiro as members of the board of executive officers (diretoria) of AWX Brasil Instituição de Pagamento Ltda., following an amendment of its articles of 26 August 2024. ¹¹

qualification

Personal tax numbers published in the notice are omitted.

documentedOn 22 January 2026 AUSTRAC's National Manager, Regulatory Operations, Bradley Brown, acting as delegate of the AUSTRAC chief executive, issued Airwallex Pty Ltd a notice under subsection 162(2) of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 stating that he had reasonable grounds to suspect that the company, a reporting entity, had contravened and/or was contravening sections 36, 41, 81 and 82 of the Act, and requiring it to appoint an external auditor. ^{1 2 3}

qualification

The notice records a suspicion that justifies an audit; it is not a finding that the Act was contravened.

outcome

Airwallex said an external auditor was appointed in February 2026, with the final report expected during the 2026 financial year. AUSTRAC has indicated that the report will inform what, if any, further action it takes and will not be made public; no result of the audit is recorded up to October 2026.

documentedThe notice requires Airwallex to engage the auditor within 14 days after AUSTRAC authorises a nominated individual, and to give AUSTRAC the audit report within 180 days of the engagement. The audit covers 1 January 2024 to the date of the notice and must assess the company's money laundering and terrorism financing risk assessment, its transaction monitoring program (including child sexual exploitation risks), suspicious matter reporting under section 41, enhanced and ongoing customer due diligence, know-your-customer controls including duplicate accounts, and AML/CTF governance and board oversight under section 81. Failure to comply with the requirement is an offence and a civil penalty provision. ¹

documentedAUSTRAC announced the order the same day, describing the audited business as the Airwallex Designated Business Group. Its chief executive Brendan Thomas said AUSTRAC takes such action where it suspects serious non-compliance, and that AUSTRAC was concerned that Airwallex's transaction monitoring program had not been attuned to the full range of risks it faces, that the company had not demonstrated an acceptable understanding of who its customers are and what reporting may be required, and about how well it identifies and reports suspicious matters and oversees these obligations. The audit is at Airwallex's expense, and its results are to inform AUSTRAC whether further regulatory action is required. ^{4 5 6 7}

qualification

These are the regulator's stated concerns at the start of an audit, not its conclusions.

response

An Airwallex spokesman said the company would cooperate, welcomed the audit as a transparent opportunity to independently validate its AML/CTF program, said it had zero tolerance for financial crime and that any customer unable to comply is promptly terminated, and that it expected the audit to validate its framework. The company also said AUSTRAC had audited its program in 2024 and an independent external auditor had validated its Australian program in 2025.

documentedIn April 2026 Airwallex appointed Carolyn Renzin, based in New York, as Chief Regulatory and Compliance Officer to lead the group's global regulatory and compliance program. A fintech trade publication reported that Jeanette Chan's title as chief legal, compliance and risk officer was changed to chief legal officer, and that the group planned to increase compliance spending by 70 per cent and its governance team by 50 per cent in 2026. ^{15 16}

documentedAirwallex announced in April 2026 that Elana Rubin AM had been appointed independent chair of its Australian board and that Sir Bill English, appointed chair of Airwallex's New Zealand board on 26 March, had joined the Australian board as an independent non-executive director, both with immediate effect. ^{17 14}

qualification

The announcement does not name the legal entity whose board this is. A Wesfarmers notice of September 2026 lists English as a director of Airwallex Holdings (Australia) Pty Ltd and chairman of Airwallex (New Zealand) Limited, both since March 2026, and does not list Airwallex Pty Ltd.

documentedAirwallex said in 2021 that it had more than 40 banking partners worldwide. Its current customer-funds page says the group partners with banks around the world, names DBS, J.P. Morgan, Standard Chartered and ANZ among them, and offers customers the ability to spread funds across more than 60 banking partners. ^{1 3}

documentedIn the United States, the group's customer-funds page says Evolve Bank & Trust, a member of the FDIC, provides payment services to certain US customers as an Airwallex partner bank and holds their funds in an omnibus account for the benefit of Airwallex's customers, eligible for FDIC pass-through insurance. ³

documentedAirwallex launched its Yield product for Australian customers in 2024 in partnership with J.P. Morgan, offering a return on Australian and US dollar balances. ⁴

qualification

The company's statement as reported by an accounting trade publication on 1 July 2024.

documentedIn May 2021 Airwallex described itself as a principal member of Visa and Mastercard when it launched online card acceptance in Hong Kong, after the same service started in the United Kingdom and Europe in September 2020. ⁵

documentedA technology news site reported in April 2020 that Airwallex had introduced Borderless Cards in partnership with Visa and an integration with the accounting platform Xero, and in March 2019 that Airwallex plugged into partners such as Stripe to offer other financial services. ^{6 7}

qualification

Press reports based on company announcements; the contractual terms are not described.

documentedA fintech trade publication reported in November 2021 that Airwallex business accounts connect with online stores such as eBay, Shopify and PayPal and with accounting packages such as Xero. ⁸

qualification

A trade-press summary; how each integration works is not described.

documentedBrex's legal terms, in a version dated 5 November 2024, provide that participation in the Brex card program in the European Union is governed by Airwallex EU Card Terms, with Airwallex acting as the card issuer partner. ⁹

qualification

The terms do not name which Airwallex company issues the cards.

documentedAirwallex's newsroom lists a collaboration with Visa on payments for freight platforms announced on 23 July 2026 and, on 13 August 2026, the addition of Affirm's pay-over-time options for US shoppers of Airwallex merchants. ^{10 11}

documentedJack Zhang told a technology news site in 2017 that Airwallex was already working with Tencent to lower back-end costs for its WeChat Pay service overseas, and that it made sense to take strategic investment from Tencent because of the WeChat ecosystem. ¹²

qualification

Zhang's own description in a 2017 interview; no agreement is among the retained records.

documentedAccounts of Airwallex's founding differ in the number of founders. A technology news site in 2019 named four co-founders, Xijing Dai, Jack Zhang, Lucy Liu and Max Li, who started the company in Melbourne in 2015; a US business magazine names Jacob Dai, Lucy Liu and Max Li as Zhang's co-founders. An Australian newspaper in 2026 and a personal-finance magazine name five: Jack Zhang, Max Li, Lucy Liu, Xijing Dai and Ki-lok Wong. ^{1 2 3 4}

qualification

Jacob Dai and Xijing Dai are the same person; the Companies House record of Xijing Dai is used for the name. Ki-lok Wong's role is not described further in the retained records.

documentedJack Zhang is a co-founder and the chief executive of Airwallex. Before founding it he worked at the Australian banks ANZ and NAB; Airwallex's 2016 announcement describes him as a former ANZ and NAB foreign exchange solution designer, and a business magazine reports that he traded foreign currencies at National Australia Bank. ^{5 1 6}

documentedLucy Liu is a co-founder and the president of Airwallex, listed in a business magazine's 2025 ranking of the most powerful women in Asia, with Singapore as her country. Before Airwallex she worked at Barclays in Hong Kong and as an investment consultant at the investment bank CICC in Shanghai, which she left in 2015. ^{7 8}

qualification

Biographical details are from magazine profiles; personal details beyond her career are omitted.

documentedKai Wu was Airwallex's Greater China chief executive in May 2021 and was appointed chief revenue officer and Asia-Pacific general manager in December 2022, the group's first Singapore-based C-suite executive, after about five years in roles that included chief financial officer, according to a Singapore fintech news site. ^{9 10 11}

qualification

Titles and dates come from a company announcement and trade press; the employing company is not named.

documentedArnold Chan is Airwallex's Asia-Pacific general manager. A human-resources trade publication reported that he joined about five years earlier to lead the SME business in Hong Kong and now oversees more than 200 commercial staff across the region. ^{5 12}

qualification

Based on an interview profile; the employing company is not named.

documentedAccording to a September 2022 press release of Tencent Music Entertainment Group, filed with the SEC, Jeanette Kim Yum Chan was then Chief Legal, Compliance and Risk Officer at Airwallex, which she joined in 2019 after serving from 1986 to 2019 as managing partner of the China practice of the law firm Paul, Weiss, Rifkind, Wharton & Garrison, and was appointed an independent director of Tencent Music Entertainment Group (NYSE: TME). ¹³

documentedAirwallex appointed James Teodorini head of its Australian and New Zealand operations in January 2026, replacing Luke Latham, who had left as ANZ general manager at the end of 2024. Teodorini joined from the money-transfer group Thunes, where he led Asia-Pacific, and had previously worked with Currencycloud and Visa Direct while based in Singapore. ⁵

qualification

From a business news report; the employing company is not named.

documentedJames Teodorini signed Airwallex Pty Ltd's modern slavery statement as "Director, Airwallex Pty Ltd" on 18 June 2026. ¹⁴

documentedThe New Zealand companies register, as reproduced by a commercial site, lists three directors of Airwallex (New Zealand) Limited: James Alan Charles Teodorini (appointed 5 March 2026), Lowry Andersen Gladwell (19 March 2026) and Simon William English (20 March 2026). Searches of the same site find no other New Zealand directorships or shareholdings for Teodorini or Gladwell. ^{15 16 17}

documentedA New Zealand newspaper reported on 20 March 2025 that Airwallex had hired the Auckland-based Lowry Gladwell as its New Zealand lead and first local staff member; he had previously been head of strategic partnerships at Xero and head of Asia-Pacific partnerships at Lightspeed. ¹⁸

qualification

From a newspaper report, which does not name the employing company.

documentedAn Australian financial newspaper described the new board as one that will oversee Airwallex Australia's governance and report to the parent company led by co-founder Jack Zhang. Zhang said the appointments would bring deep governance and business expertise. ^{19 20}

qualification

The newspaper's description of the reporting line; the board's legal entity is not named.

documentedWesfarmers' notice of its 2026 annual general meeting lists among Simon William (Bill) English's current directorships Chairman of Airwallex (New Zealand) Limited and Director of Airwallex Holdings (Australia) Pty Ltd, each since March 2026; English has been a non-executive director of Wesfarmers since April 2018. ²¹

documentedElana Rubin is a non-executive member of the Reserve Bank of Australia's Governance Board and served on the Reserve Bank Board from 31 August 2023 to 28 February 2025. The RBA lists her previous roles as chair of Afterpay, AustralianSuper and WorkSafe Victoria and director of Mirvac and ME Bank; Airwallex's announcement adds that she is a non-executive director of Dexus and chair of the Australian Business Growth Fund and Infoxchange. ^{22 20}

documentedSir Bill English (Simon William English) was Minister of Finance and Deputy Prime Minister of New Zealand from 2008 to 2016 and the 39th Prime Minister until October 2017, and left parliament in March 2018. Besides Wesfarmers, he chairs Mount Cook Alpine Salmon and Precision Technology Group and is a director of the Paul Ramsay Foundation, the Centre for Independent Studies, The Todd Corporation and other organisations. ^{23 20 24 21}

qualification

His other New Zealand company interests, including family companies, are listed in public registers and are not part of this dossier.

documentedA board biography of Ian Osborne, co-founder of Hedosophia, published by a listed company of which he is a non-executive director, lists Airwallex (Cayman) Limited among his current directorships. Osborne set up the consultancy Osborne and Partners in 2009, taking on DST Global as a client, and co-founded Hedosophia, of which he is chief executive. ^{25 26}

documentedA venture database describes Huashan Capital One as a Shanghai-based angel investment group whose latest recorded investment was the US$3 million Airwallex round of 5 July 2016. ²

qualification

A commercial database profile; Huashan's registration details are not given.

documentedA search of a public Australian legal information database for "Airwallex" returned nine documents: three Senate select committee reports on financial technology (2020 and 2021), two law journal articles, and four decisions, [2024] VCC 1323, Re Eratos Group Pty Ltd (in liq) [2025] VSC 755, [2026] ARTA 498 and [2026] FWC 2120. Airwallex is not named as a party in any of them. ³

qualification

A search of one legal database; it does not establish that no other proceedings exist, for example outside Australia or unreported.

documentedIn [2024] VCC 1323 the County Court of Victoria, sentencing on 23 August 2024 a man who had pleaded guilty to dealing with money he believed to be proceeds of indictable crime worth $100,000 or more and to drug offences, recorded that on 24 November 2021 he transferred 211,698.30 yuan (about $45,860) from the Airwallex account of his trading company to a Chinese bank account and $4,000 from the same account to his wife's account; these transactions formed part of the money-dealing charge. ^{4 5}

qualification

Airwallex was not a party; the decision does not discuss Airwallex's conduct or name the Airwallex company that held the account.

documentedIn Re Eratos Group Pty Ltd (in liq) [2025] VSC 755 (Supreme Court of Victoria, 5 December 2025) the court noted that the director's report on the affairs of Eratos (Aust) Pty Ltd disclosed two bank accounts, with Bank Australia and Airwallex, holding $53,863 in total. ⁶

qualification

Airwallex appears only as an account provider; no claim against it was before the court.

documentedIn [2026] ARTA 498 (13 March 2026) the Administrative Review Tribunal relied on Airwallex account statements showing deposits of $21,107.33 as evidence of a taxpayer's income. ⁷

qualification

Airwallex was not a party and the tribunal made no finding about it.

documentedAn Australian financial newspaper reported in July 2023 that Airwallex Pty Ltd's 2022 accounts lodged with ASIC showed revenue of A$59.3 million and profit of A$17.5 million, of which A$41 million came from charging clients for technology development and support services, A$8 million from payment and currency conversion fees, A$7 million from issuing services and A$2 million uncategorised, and that the company held A$502 million for its clients at 31 December 2022. ¹

qualification

Figures as reported by the newspaper from the ASIC filing, which is not among the retained records.

documentedAccording to a national newspaper report republished by a business news site in May 2026, accounts filed on 30 April 2026 show that revenue from Airwallex's Australian operations rose 30 per cent in 2025 to A$105.6 million while the loss widened to A$17.2 million from A$12.8 million in 2024. Employee benefits rose 22.5 per cent to A$69.9 million, advertising more than 61 per cent to A$14.9 million and transaction processing costs to A$47.5 million from A$32.8 million; total equity fell from A$93 million to A$67 million, accumulated losses reached A$70.4 million and cash was A$721.8 million. ²

qualification

The article does not name the reporting entity or say whether the cash figure includes client money; the filing is not among the retained records.

response

James Teodorini, Airwallex's ANZ general manager, said 2025 was a year of meaningful progress and continued investment in Australia, with strong revenue growth and deliberate investment in talent and capability.

documentedAnnouncing its Australian board appointments, Airwallex said it served more than 40,000 Australian businesses, including Qantas, Canva, CultureAmp and Afterpay, and facilitated more than A$39 billion of payments for Australian customers a year. ³

qualification

Company figures.

documentedIn mid-2024 Airwallex said its revenue across the Australian and New Zealand business had risen 93 per cent in the previous year, with global revenue up 84 per cent and transaction volumes up 68 per cent. ⁴

qualification

Company growth rates without amounts, as reported by a trade publication.

documentedThe group's reported scale has grown from annualised revenue above US$100 million in late 2021, with revenue up 184 per cent year on year by October 2022, to US$720 million in March 2025, when annualised payments volume exceeded US$130 billion, and above US$1 billion in October 2025, with annualised transaction volume above US$235 billion, according to the company. A business magazine reported that by March 2026 the group processed more than US$250 billion a year at a revenue run-rate of US$1.3 billion and was not yet profitable. ^{5 6 7 8 9}

qualification

Company and press figures for the group as a whole, not audited accounts.

documentedAn Australian newspaper reported in January 2026, citing unreported quarterly results relayed by a person familiar with the business, that Airwallex processed US$61 billion of payments in the fourth quarter of 2025, that annualised revenue rose 79 per cent to about US$1.1 billion and that the quarter's gross profit was almost US$150 million, with a small loss after most costs. ¹⁰

qualification

Airwallex did not comment on these figures.

documentedIn August 2026 Lucy Liu told a business magazine the company was EBITDA positive with a healthy gross margin, declining to give specific profitability figures. ¹¹

qualification

An executive's statement; no financial statements of the group are among the retained records.