AUSTRAC has published its regulatory expectations for the implementation of the 2024 amendments to the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act). Background.

The changes 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 jewellery industries that are newly coming under regulation (tranche 2).

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

• continue to implement their current money laundering controls;
• develop and document implementation plans that manage their ML/TF/PF risks while they transition their policies, procedures and systems to meet the obligations under the reformed AML/CTF Act;
• show sustained effort and progress against their implementation plans;
• continue to manage their 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 their systems and controls are effective – they continue to manage their ML/TF risks while embedding reform-related changes;
• if their systems and controls are not effective now, or they are ignoring their obligations – they update their systems and controls so they are effective.

For those businesses that will come under regulation from 1 July 2026, AUSTRAC expects that by 1 July 2026, they will:

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

AUSTRAC says it does not expect newly regulated businesses to be perfect at identifying and controlling for money laundering risks from day one. It does expect honest efforts to meet their 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; or
  * who AUSTRAC suspects are complicit with, or wilfully blind to, money laundering in their business.

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