Nils Silinevics
Partner · AML & Crypto Compliance · Former FIU Investigator
Exodus is a non-custodial wallet — AUSTRAC (financial intelligence) + ASIC (corporate regulator) does not regulate it. But if you send funds to an exchange, the exchange can freeze them. Here's how to protect yourself and what to do if it happens.
Exodus is non-custodial — AUSTRAC does not regulate self-custody wallets
AUSTRAC requires crypto exchanges to register as 'digital currency exchange (DCE) providers' — mandatory since 2018; ASIC regulates crypto investment products
This matters because it determines which regulatory body has authority over your case — and whether you have a direct complaint path or need cross-jurisdictional legal action.
What this means for you: Exodus is non-custodial — AUSTRAC (financial intelligence) + ASIC (corporate regulator) does not regulate it. Your wallet cannot be frozen. However, if you send funds to a centralized exchange, the exchange can freeze them. The issue is not with Exodus but with the receiving exchange.
under AML/CTF Act, you can complain to AUSTRAC; also AFCA (Australian Financial Complaints Authority) for consumer disputes
Under Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act), Exodus must conduct customer due diligence and can freeze accounts during AML investigations. However, they must also:
If Exodus doesn't meet these obligations, we escalate to AUSTRAC (financial intelligence) + ASIC (corporate regulator) and file a formal legal submission. For a broader comparison of how Australia's rules stack up against other jurisdictions, see our AML laws by country reference.
capital gains tax (CGT) — 50% discount if held >12 months; income tax if trading as business
If your Exodus account is frozen, you may still need to declare your crypto holdings on your Australia tax return — even if you can't access them. Under Australia law, the tax obligation may apply regardless of whether the funds are accessible. We recommend consulting a Australian tax advisor.
If the freeze causes you to miss a tax deadline, we can provide documentation for the AUSTRAC (financial intelligence) + ASIC (corporate regulator) and tax authority explaining the situation.
A Australian user of Exodus (non-custodial wallet) tried to send funds to an exchange, but the exchange froze the deposit citing Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act). The exchange flagged the Exodus address as high-risk. We prepared documentation showing legitimate acquisition of funds. Within 14 days, Exodus released the funds after our submission demonstrated compliance with Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act).
Details anonymized to protect client confidentiality. Swiss professional secrecy applies.
We analyze your Exodus account, transaction history, and Australia regulatory context to identify the exact trigger. Was it a none (non-custodial) risk flag? A sanctions screening match? A source-of-funds demand? Each requires a different strategy.
We prepare documentation compliant with Anti-Money Laundering and Counter-Terrorism Financing Act 2006 — not just Exodus's standard templates. This includes source-of-funds proof, transaction tracing, and any required AUSTRAC-specific forms.
We submit through Exodus's compliance channels — not standard support. Our submission is in English and references AUSTRAC guidelines. We coordinate with AUSTRAC even though Exodus is not registered.
We verify everything works and advise on preventing recurrence on Exodus. If Exodus doesn't respond within no statutory maximum; AUSTRAC expects compliance review within 14 days, we escalate to AUSTRAC and pursue cross-jurisdictional action in USA (Nebraska; publicly traded: EXOD) if needed.
Tell us what happened. A senior crypto compliance lawyer — not a chatbot, not a junior — will read your case and respond within 6 hours. Swiss professional secrecy applies from your first message.