--- title: "Airwallex Pty Ltd: ownership, licences and regulatory scrutiny" language: en canonical: https://dossiertwist.com/dossiers/airwallex-pty-ltd/ as_of: 2026-10-17 keywords: ["Airwallex Pty Ltd","ACN 609 653 312","Airwallex (Cayman) Limited","Airwallex Capital Pty Ltd","Airwallex SVF Pty Ltd","Airwallex Holdings (Australia) Pty Ltd","AFSL 487221","AUSTRAC external audit","designated business group","Jack Zhang","Lucy Liu","Airwallex (UK) Limited","Airwallex Global Limited","AWX Brasil Instituição de Pagamento","Tencent","HongShan","Square Peg","cross-border payments","electronic money institution","Series H"] --- # Airwallex Pty Ltd: ownership, licences and regulatory scrutiny **Question.** Who owns and controls Airwallex Pty Ltd, how is the Airwallex group funded and licensed, and what scrutiny has it faced? **Answer.** Airwallex Pty Ltd (ACN 609 653 312) is the Melbourne company in which the Airwallex payments group was founded in 2015, and it holds Australian financial services licence 487221. A 2025 fund disclosure describes it as wholly owned by Airwallex (Cayman) Limited, the group's holding company. The group has raised venture funding from investors including Tencent, HongShan, Square Peg and Addition, most recently at an US$11 billion valuation in June 2026. In January 2026 AUSTRAC said it had reasonable grounds to suspect contraventions of the anti-money laundering law and required an external audit, whose report will not be made public; the company said it welcomed the audit. The company has rejected earlier press accounts of bank exits and US allegations about its China ties, and the retained records contain no decision by a US authority on those allegations. ## What this research adds - Analysis: Airwallex Pty Ltd, founded in Melbourne in 2015, is described in a 2025 fund disclosure as wholly owned by Airwallex (Cayman) Limited; according to a 2023 newspaper report it moved its New Zealand and Indian businesses to the Cayman Islands on 1 January 2023, and in 2026 Jack Zhang was the sole subscriber of a new financial services holding company in London. The dossier sets the group's funding rounds and licensed companies against the records that confirm them, and keeps AUSTRAC's January 2026 audit notice, the 2021 reports on NAB and Citi and the US allegations about China ties beside the company's responses and the absence of any recorded outcome. [src-001] [src-009] [src-002] [src-106] [src-003] [src-018] [src-030] [src-049] [src-024] [src-072] [src-027] [src-084] [src-086] [src-092] [src-014] [src-012] [src-075] [src-074] [src-046] [src-071] [src-006] [src-032] [src-037] [src-004] [src-039] ## The company - Analysis: Airwallex Pty Ltd is an Australian private company with ACN 609 653 312 and ABN 37 609 653 312; the Australian Business Register records its name as unchanged since 3 December 2015 and its main business location as Victorian postcode 3000 since 22 March 2019. AUSTRAC addressed its January 2026 notice to the company at Level 7, 15 William Street, Melbourne. Its modern slavery statement for 2025 says it 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. The company has held Australian financial services licence 487221 since 5 September 2016, covering general advice on, dealing in and issuing non-cash payment products and foreign exchange contracts, and making a market in foreign exchange contracts. [src-001] [src-009] [src-002] [src-106] ## Owners and funding - Analysis: A product disclosure statement of 4 August 2025 for the Airwallex Yield Liquidity Fund, whose investment manager is Airwallex Capital Pty Ltd, states that Airwallex Pty Ltd and Airwallex Capital are wholly owned subsidiaries of Airwallex (Cayman) Limited (registration No. 307718). That company is incorporated in the Cayman Islands and, according to a fund's report filed with the SEC, has operations in Singapore and the United States. Press accounts place the group's headquarters in Melbourne until 2018, in Hong Kong until 2023 and then in Singapore; in December 2025 the group named San Francisco as a second global headquarters, and an Australian newspaper described the group in 2026 as officially domiciled in the Cayman Islands. [src-003] [src-018] [src-030] [src-049] [src-024] [src-072] [src-027] - Analysis: The group has announced venture rounds since 2016. In June 2026 it announced US$320 million of Series H funding at an US$11 billion valuation, led by the returning investor Addition. No share register of the Cayman company is among the retained records, so the size of holdings rests on reported figures: a US business magazine put Jack Zhang's stake at 12 per cent, and Senator Tom Cotton's June 2026 letter says Tencent and HongShan reportedly hold a combined stake of more than 20 per cent. Zhang has said that Tencent holds a passive stake of less than 10 per cent and does not have a board seat, a statement a business magazine reports from the company's published response; neither figure comes from a share register. [src-024] [src-027] [src-084] [src-086] ## Regulatory scrutiny and disputed reports - Analysis: On 22 January 2026 a delegate of AUSTRAC's chief executive issued Airwallex Pty Ltd a notice under subsection 162(2) of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, stating reasonable grounds to suspect that it had contravened or was contravening sections 36, 41, 81 and 82 of the Act and requiring it to appoint an external auditor. The notice records a suspicion that justifies an audit; it is not a finding that the Act was contravened. AUSTRAC's chief executive Brendan Thomas said the agency takes such action where it suspects serious non-compliance and was concerned about the company's transaction monitoring, its understanding of who its customers are and how it identifies and reports suspicious matters; these are the regulator's concerns at the start of an audit, not its conclusions. An Airwallex spokesman said the company would cooperate, welcomed the audit as a transparent opportunity to independently validate its program, had zero tolerance for financial crime, promptly terminates any customer unable to comply and expected the audit to validate its framework; the company added that AUSTRAC had audited its program in 2024 and an independent external auditor had validated its Australian program in 2025. According to the company an auditor was appointed in February 2026; AUSTRAC has indicated that the report will inform what, if any, further action it takes and will not be made public, and no result is recorded up to October 2026. [src-009] [src-092] [src-072] [src-014] [src-012] [src-075] [src-074] - Analysis: Two Australian newspapers reported in April 2021 that National Australia Bank had cancelled transactional banking services for Airwallex's customers in 2018 and that Citigroup later declined its application for banking services. NAB had cited a policy of limiting exposure to low-revenue money services businesses, while unnamed sources linked the decision to red flags about Airwallex's customers and transaction patterns, and Citi said Airwallex did not meet its risk criteria. The newspapers said they did not suggest that Airwallex facilitated money laundering, only that other banks had concerns about its ability to comply with anti-money laundering laws. Airwallex said it did not cut corners, was not aware of any concerns from NAB about payment transfers, said there was no instance of Citigroup rejecting it over any concerns and was in ongoing dialogue with Citi. Both banks approached Airwallex for possible business in 2020; NAB ended those discussions in October 2020 and the Citi enquiries led to no business, according to the newspapers. [src-046] [src-071] - Analysis: In December 2025 the venture capitalist Keith Rabois, a board director of the competing fintech Ramp, alleged that Airwallex was sending its US customers' data to China, claiming that its employee base in China and partial ownership by Tencent and HongShan legally required it to hand US customer data to the Chinese government on request; the allegation was reported by a business magazine, and no authority has made such a finding in the retained records. Zhang denied it, said Airwallex's Chinese engineers had no access to foreign user data and accused Rabois of circulating inaccurate claims for the benefit of one of his portfolio companies; in June 2026 he called the allegations "patently false" and wrote that US customer data is stored in the United States and cannot be accessed by staff based in China and Hong Kong. On 17 June 2026 Senator Cotton asked the Committee on Foreign Investment in the United States to review Chinese investment in Airwallex; the letter's statements are the senator's assertions, and no CFIUS decision is in the retained records. Lucy Liu declined to address the letter directly and referred to an earlier company statement; Zhang, who has called the allegations false, says Tencent's stake is passive and below 10 per cent; and Airwallex invited third-party firms to audit its privacy and data controls and published a security assessment by Coalfire. [src-024] [src-074] [src-086] [src-084] ## Directors and boards - Analysis: Jack Zhang is a co-founder and the chief executive of Airwallex. James Teodorini signed Airwallex Pty Ltd's 2025 modern slavery statement as "Director, Airwallex Pty Ltd" on 18 June 2026. In April 2026 the group announced that Elana Rubin had been appointed independent chair of its Australian board and that Sir Bill English, appointed chair of its New Zealand board on 26 March, had joined the Australian board as an independent non-executive director. 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. [src-006] [src-032] [src-037] [src-002] [src-004] [src-039] ## Sources - [src-001] ABN Lookup: historical details for ABN 37 609 653 312 (AIRWALLEX PTY LTD), Australian Business Register, 2026-10-17 - [src-009] AUSTRAC notice to appoint an external auditor under subsection 162(2) AML/CTF Act: Airwallex Pty Ltd, Australian Transaction Reports and Analysis Centre, 2026-01-22 - [src-002] Modern Slavery Statement of Airwallex Pty Ltd for the year ended 31 December 2025, Australian Government Modern Slavery Register, 2026-06-18 - [src-106] ASIC AFS licensee register dataset: records matching "Airwallex", data.gov.au (Australian Securities and Investments Commission dataset), 2026-10-17 - [src-003] Company statement source · src-003 - [src-018] Robinhood Ventures Fund I, Form N-CSR certified shareholder report for the period ended 31 March 2026, U.S. Securities and Exchange Commission (EDGAR), 2026-03-31 - [src-030] Media source · src-030 - [src-049] Media source · src-049 - [src-024] Media source · src-024 - [src-072] Media source · src-072 - [src-027] Company statement source · src-027 - [src-084] Media source · src-084 - [src-086] Senator Tom Cotton press release and letter to Treasury Secretary Bessent on Airwallex, Office of U.S. Senator Tom Cotton, 2026-06-17 - [src-092] Media source · src-092 - [src-014] AUSTRAC media release: AUSTRAC orders audit of Airwallex for suspected AML/CTF compliance failures, Australian Transaction Reports and Analysis Centre, 2026-01-22 - [src-012] Media source · src-012 - [src-075] Media source · src-075 - [src-074] Media source · src-074 - [src-046] Media source · src-046 - [src-071] Media source · src-071 - [src-006] Media source · src-006 - [src-032] Media source · src-032 - [src-037] Company statement source · src-037 - [src-004] Company statement source · src-004 - [src-039] Media source · src-039