What Records Should an Australian Charity Keep When Sending Money Overseas?
Last updated: 25 October 2026.
If your charity sends even a small amount of money overseas, you are covered by the ACNC External Conduct Standards, and those standards come with specific record-keeping expectations. Many treasurers only discover this when a board member asks, “Could we show the ACNC where every dollar sent to our partner went?” This guide sets out what the ACNC says to keep, how long to keep it, and how to organise it so that you can answer that question in an afternoon rather than a month.
It is general information drawn from ACNC guidance (checked 25 October 2026), not legal advice. If your overseas activity is significant, or your funding passes through several partners, get advice from a lawyer who knows charity law and international sanctions. We prepare and organise the financial side of this record-keeping. We do not provide legal opinions.
The short version: for each financial year in which you operate overseas or give funds or resources to third parties for use overseas, keep records that let you summarise your activities and spending country by country, plus the paperwork behind each transfer and each partner, for at least seven years.
Does this apply to us?
Almost certainly, if you send money abroad. The ACNC says a charity is generally considered to operate outside Australia even if its overseas activities are just a minor part of its work, or if it only sends a small amount of money overseas, including through a third party. Basic Religious Charities must also comply with the External Conduct Standards if they operate outside Australia, even though they do not have to comply with the Governance Standards. Charities that do not operate outside Australia are not subject to the standards. A narrow exception applies where overseas activities are directly related to a purpose intended to benefit people in Australia and are an incidental part of operations, so read the ACNC’s guidance on when the standards apply if that might describe you.
What the ACNC says to keep
External Conduct Standard 2 requires a charity to obtain and keep records for its operations outside Australia, for each financial year in which it operates outside Australia or gives funds or other resources to third parties for use outside Australia. The records must include the information needed to prepare a summary of its activities and related spending on a country-by-country basis. The ACNC says a charity is likely to meet the standard if its records contain:
- the types of activities it conducted outside Australia, country by country;
- how those activities enabled it to pursue and achieve its purpose, country by country;
- details of all expenditure relating to its overseas activities, country by country;
- details of the procedures and processes it used to monitor its overseas operations;
- a list of the third parties it worked with outside Australia; and
- details of any documented claims of inappropriate behaviour by its employees or Responsible People outside Australia, and the actions taken in response.
The ACNC says records should be complete, accurate and legible, prepared on a timely basis, kept in English or in a form that can easily be translated into English, stored safely, and kept for at least seven years. They can be in any format, provided specific information is easy to find if requested. The ACNC does not require you to send these records in, but it may request them in an enquiry or investigation, and it expects you to provide them in a timely manner.
The paperwork behind each transfer and partner
Standard 1 is about control of funds, and its examples of reasonable steps tell you which documents will exist if you follow it. Those documents are also the records you will want if you are ever asked to explain a transfer.
| Record | Why it matters |
|---|---|
| Board or committee approval of each project and funding request, with minutes | The ACNC lists properly approved overseas activities and funding requests, with records of decisions, and approval by more than one person, as reasonable steps |
| Written agreement with each partner, setting out roles and responsibilities | Listed by the ACNC as a reasonable step, and a record of what was agreed |
| Due diligence on the partner (see our article on checks before funding an overseas partner) | The ACNC suggests keeping copies of searches such as sanctions and terrorist-list checks, and a risk register |
| Bank transfer records and the partner’s confirmation of receipt | The ACNC suggests secure, monitored services such as formal banking and asking recipients to confirm receipt |
| Budgets for each project, progress reports and financial reports from the partner | The ACNC suggests monitoring through regular reports on progress and finances, reviewed at board meetings |
| Receipts, acquittals or expense reports showing how funds were applied | Supports the “details of all expenditure” requirement |
| Register of equipment sent or bought for overseas use | Listed by the ACNC as a reasonable step |
| Records of concerns, complaints and how they were handled | Standard 2 expects documented claims of inappropriate behaviour and your response to be recorded |
| Sanctions and terrorism-financing checks | The ACNC says to retain checks and risk assessments completed on sanctions and listed organisations |
How to organise it: one folder per country, one sub-folder per partner
The “country by country” requirement points to a simple structure.
- Top level: financial year, then country. Each country folder holds a one-page summary: activities, total spend, partners, monitoring done.
- Inside each country: one folder per partner or project. Agreement, due diligence, approvals, transfer evidence, reports, acquittals.
- Central register: a spreadsheet or accounting-system report listing every transfer by date, country, partner, project, amount in Australian dollars, the foreign currency amount and exchange rate where relevant, and the approval reference.
- Standing folder for policies: overseas funding policy, partner assessment process, safeguarding and anti-fraud policies, conflicts of interest register.
Using an accounting system, code each overseas transfer to an expense account and a tracking category for country and project, so that “expenditure by country” is a report rather than a research project. Our guide to setting up Xero for a charity explains tracking categories, and our guide to ACNC financial reports shows where your overall figures end up.
Transfers and cash
The ACNC recommends formal banking facilities where they exist and are available, as the safest means of transferring charitable funds. If large payments are made in cash, the ACNC says the charity should be able to demonstrate why cash was chosen over safer options, keep detailed records, ensure the payee is legitimate and show how it manages the risk. If you use a remittance service provider, the ACNC recommends checking that it is registered with AUSTRAC.
How long to keep records
At least seven years, according to both the ACNC’s general record-keeping guidance and its External Conduct Standard 2 guidance. The ACNC notes that after seven years, and if you have no record-keeping obligations to other regulators, you can destroy records kept for ACNC purposes. Other regulators, funders or your own constitution may require longer, so check your grant agreements. For ATO rules, see our guide to how long to keep business records.
A quarterly check that keeps you ready
- Do the transfers in the bank match approved amounts and the central register?
- Has every partner confirmed receipt and provided their latest report?
- Is each partner’s due diligence still current, and has anything changed?
- Are expenditure figures by country reconciled to the ledger?
- Has the board reviewed progress reports, with that review minuted?
How we help
We help charities build the financial side of overseas record-keeping: coding by country and project, a clean transfer register, board-ready reports and records that line up with your ACNC reporting. See our charities and NFPs page, try the free Charity Health Check, or email info@guidancegrowth.com.au. We organise and prepare your records. Legal advice on sanctions and overseas law comes from a lawyer.
Frequently asked questions
Do small transfers overseas trigger the ACNC External Conduct Standards?
Yes. The ACNC says a charity is generally considered to operate outside Australia even if its overseas activities are a minor part of its work or it only sends a small amount of money overseas, including through a third party.
What records does ACNC External Conduct Standard 2 require?
Records that let you summarise activities and spending country by country, including activity types, how they furthered your purpose, all overseas expenditure, monitoring procedures, a list of third parties and documented claims of inappropriate behaviour with your response.
How long must we keep records of overseas activities?
At least seven years, according to the ACNC. Other regulators or funders may require longer.
Do we have to send our overseas records to the ACNC?
No. The ACNC does not require you to provide them routinely, but it may request them as part of an enquiry or investigation, and expects you to provide them in a timely manner.
Should we send money overseas in cash?
The ACNC recommends formal banking facilities where available. If large payments are made in cash, you should be able to show why, keep detailed records and demonstrate how you manage the risk.
What should we keep about our overseas partner?
Approvals and minutes, the written agreement, due diligence evidence, transfer and receipt confirmations, budgets, progress and financial reports, and records of any concerns raised and how they were handled.
Sources and further reading
- ACNC: External Conduct Standards overview (checked 25 October 2026)
- ACNC: External Conduct Standard 1: Activities and control of resources (checked 25 October 2026)
- ACNC: External Conduct Standard 2: Annual review of overseas activities and record-keeping (checked 25 October 2026)
- ACNC: Charities operating overseas (checked 25 October 2026)
- ACNC: Protecting your charity from terrorism financing risks (checked 25 October 2026)
- ACNC: Keeping charity records (checked 25 October 2026)
This article is general information, not personal advice. Rules and dates can change, so check ato.gov.au or acnc.gov.au for the latest, or speak to us about your situation.