AUSTRAC regulatory expectations for the implementation of the AML/CTF reforms

The reforms to the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act) will commence on: 

  • 31 March 2026 for businesses that are currently regulated
  • 1 July 2026 for those businesses in the legal, accounting professions, real estate and jeweller industries that are newly coming under regulation. 

We acknowledge that the timeframes set by Parliament are tight. They reflect that Australia will be subject to a mutual evaluation by the global AML body, the Financial Action Taskforce, commencing in 2026. We further acknowledge the challenges this presents for businesses preparing for the reforms.

The AML/CTF reforms place the importance of risk at the heart of our AML approach in Australia. AUSTRAC is evolving its regulatory approach to also focus on reducing the harm of money laundering, terrorism and proliferation financing (ML/TF/PF) as well as other serious financial crime. As we approach the commencement dates for the AML/CTF reforms, AUSTRAC’s expectations as a regulator are informed by: 

  • the real financial crime risks that businesses need to manage
  • the time available to prepare before the AML/CTF reforms commence. 

Keeping Australia safe from criminal harm is our primary goal. AUSTRAC does not expect perfection on day one. However, we do expect you to maintain your focus on reducing your money laundering risks. The core principles of identifying, mitigating and managing those risks remain unchanged. We recommend businesses resist the urge to implement programs or processes that may create the impressions of compliance with the AML/CTF Act, but have minimal impact on the risk of money laundering.

For businesses that are currently regulated, AUSTRAC expects you to:

  • continue to implement your current money laundering controls
  • develop and document implementation plans that manage your ML/TF/PF risks while you transition your policies, procedures and systems to meet the obligations under the reformed AML/CTF Act
  • show sustained effort and progress against your implementation plans
  • continue to manage your ML/TF risks through the changes, including implementing any tactical improvements in the short term
  • act now to review and strengthen existing frameworks, systems and processes for managing ML/TF risks.

AUSTRAC also expects that:

  • if your systems and controls are effective – you continue to manage your ML/TF risks while embedding reform-related changes
  • if your systems and controls are not effective now, or you are ignoring your obligations – you update your systems and controls so they are effective. Failing to manage your ML/TF risk is a serious regulatory concern now and will be a serious concern when the AML/CTF reforms commence. Now is the time to act.

For those businesses who will come under regulation next July, AUSTRAC expects that by 1 July 2026, you will:

  • be enrolled as a reporting entity. You will be able to access the online enrolment system from 31 March 2026
  • have an AML program, either because you have adopted the starter program provided by AUSTRAC or have developed your own. The starter program will be available in December 2025
  • have an AML/CTF Compliance Officer
  • have trained your staff on your AML/CTF program and processes
  • be ready to ask clients questions and report suspicious activity. 

We recognise that, for businesses in the newly regulated sectors, these obligations are new. For many, the concept of money laundering and its connection to crime may be new too. Organised criminals are sophisticated in their methods of hiding money and transferring value. Spotting that behaviour is a practice, which improves over time as we learn more about what money laundering looks like and how it can be controlled effectively. We do not expect newly regulated businesses to be perfect at identifying and controlling for money laundering risks from day one. We do expect honest efforts to meet your obligations and report suspicions to AUSTRAC.

After 1 July 2026, AUSTRAC will focus its enforcement in the newly regulated sectors on entities: 

  • who wilfully ignore the obligation to enrol
  • we suspect are complicit with, or wilfully blind to, money laundering in their business.

What entities can expect from AUSTRAC

As we head towards the commencement dates, AUSTRAC is committed to setting newly regulated businesses up for success with guidance (including the starter programs), education and industry forums.

AUSTRAC is evolving its regulatory approach to focus hard on reducing the harm of financially enabled crime. We are working with industry to ensure our efforts are focused on that together. We will be focusing our effort on those areas of highest harm and we will be transparent in how we use our regulatory capabilities to do that. 

July 2025

In July 2025, AUSTRAC will publish:

  • our regulatory priorities for 2025-26, which will outline the areas on which AUSTRAC will focus its regulatory efforts
  • a timeline of regulatory expectations for implementation of the AML/CTF reforms. 

This timeline will assist existing and incoming reporting entities to prepare their implementation plans for the AML/CTF reforms. It will identify by month the activities that AUSTRAC expects from reporting entities in the lead up to the commencement dates. The timeline will reflect feedback from industry association and take into account broader government reforms that may be impacting sectors.

By working together to co-design the implementation of the AML/CTF reforms, AUSTRAC and industry can protect the Australian community by reducing the risk of money laundering and the harms which arise from it.

These expectations were presented at the AUSTRAC Industry Forums on 28 May 2025. 

 

Brendan Thomas
AUSTRAC CEO
4 July 2025