Obligations for businesses currently regulated under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act) changed on 31 March 2026, and will be introduced for new businesses on 1 July 2026. This update sets out our expectations for current and new regulated businesses in meeting their obligations. In particular, it sets out our expectations on:
- managing risk
- using the program starter kits
- managing risks where there is no settled AUSTRAC position
- meeting AUSTRAC’s regulatory expectations in FY26/27.
The updated statement builds on, and should be read together with, our regulatory expectations for implementation of the AML/CTF reforms of 3 July 2025.
Managing risks – both high and low
What we expect of you
AML/CTF law requires a risk-based approach to managing money laundering, terrorism financing and proliferation financing risk. We refer to this as ML/TF risk. This means that your controls will be different for high risks and lower risks.
We expect you to remain focused on the risk of crime. Specifically, the risk that money will be laundered through your business to hide the proceeds of crime or fund further crime or terrorism. We expect you to:
- focus on strengthening your understanding of the risks your business faces
- document those risks and the controls your business puts in place to mitigate those risks.
We do not expect you to apply the same level of controls and interventions for all customers irrespective of risk. We expect that you will meaningfully consider whether simplified due diligence is appropriate and not apply a 'one size fits all' approach to customers and risks.
What you can expect of AUSTRAC
We will continue to prioritise our regulatory effort on issues that create the highest risk of crime and harm. We will look for opportunities to share insights from our intelligence about emerging risks, as well as areas of lower risk.
Use of program starter kits
What we expect of you
Each program starter kit identifies who it is for (for example, who the legal profession program starter kit is for). It does this by describing the characteristics of a business which would be suitable to use the program starter kit. We expect that you will have considered whether your business aligns with those characteristics.
What you can expect from AUSTRAC
If your business aligns with the characteristics described in the program starter kit and prepares an AML/CTF program using the kit, you can expect that our regulatory engagement with you will focus on your application of your AML/CTF program.
Our position is that, for businesses that align with the identified characteristics, the risk assessment, policies and procedures in the program starter kits are appropriate to manage the common risks faced by those businesses. We intend to regularly collect information about how the policies and procedures contained in the kits are affecting ML/TF risk. If we identify weaknesses, we intend to address that by updating the program starter kits. We will let you know if the program starter kits are updated so you can review your program.
Managing issues outside the scope of AUSTRAC materials
What we expect of you
If AUSTRAC guidance, program starter kits or other publications do not address an issue you face, we expect you to turn your own mind to the question and develop your own position. In doing so, you may wish to seek external advice.
We expect that you will document your position and why you consider it to be a reasonable position to adopt. We also expect you to retain records of any advice that has informed your position.
What you can expect of AUSTRAC
We will be transparent about our interpretation of AML/CTF law.
Our position on AML/CTF law may evolve over time. If we have a different interpretation of the law to your interpretation, we will engage in conversation, not enforcement, in the first instance.
The final decision maker on the meaning of AML/CTF laws are Australia's courts. We will update our guidance materials in line with court decisions.
Approach to regulating in FY 26/27
What we expect of you
We expect that you will meet the expectations set out in the regulator statement of expectations.
We expect newly-regulated businesses to:
- be enrolled
- have an AML/CTF program and AML compliance officer
- train your staff on your program
- be ready to have a go at reporting when a suspicious matter arises.
We expect current reporting entities to either:
- be managing ML/TF risks and reporting in accordance with the reformed obligations
- have an implementation plan and be making progress on it.
We recognise that, after 1 July 2026, reporting entities will continue to embed practices and processes to implement the AML/CTF reforms. We expect reporting entities will improve the quality of controls and reports over time and we expect effort, not perfection, during FY26/27.
What you can expect of us
We are currently developing our regulatory priorities for FY 26/27. You can read our regulatory priorities for FY 25/26.
Our regulator statement of expectations is relevant to the development of our regulatory priorities for FY26/27. We expect our regulatory effort in FY26/27 to include focus on achieving the following outcomes:
- Understanding newly regulated industries, sectors and businesses in greater depth through engagement, education and supervision.
- Connecting current and newly regulated businesses to the guidance, education and the program starter kit materials produced to date.
- Checking that current reporting entities have, and are progressing against, implementation plans to move from their current state to meeting the reformed obligations.
- Checking that new regulated businesses are meeting the expectations of:
- being enrolled
- having an AML/CTF program and AML compliance officer
- training your staff on your program
- being ready to have a go at reporting when a suspicious matter arises.
- We will take early enforcement action against businesses who fail to enrol and regulated businesses we suspect have been complicit in money laundering.