Insights from the recent ACAMS industry session: AML/CTF Reform Australia

Big changes are coming to Australia’s anti-money laundering and counter-terrorism financing (AML/CTF) laws. These changes aim to strengthen how businesses detect and prevent financial crime.

At a recent ACAMS industry event, experts came together to explain what’s changing and what businesses need to do to get ready. Whether you’re new to AML/CTF or part of an industry that will soon be regulated (such as legal, real estate, or accounting), here’s what you need to know.

Start preparing now — don’t wait

The new laws and rules haven’t been finalised yet, but that doesn’t mean you should wait. You can (and should) start planning now.

Begin by reviewing how your business handles risk and who’s responsible for AML/CTF compliance. Make sure your key roles and responsibilities are clearly defined, including who will act as your AML Compliance Officer and who will sit on your governing body or board.

The AML Compliance Officer role is changing

The AML Compliance Officer will have more responsibility under the new rules. They’ll be expected to lead the day-to-day running of your AML/CTF program and have direct access to senior leadership (like the board).

If you’re appointing someone to this role, make sure they have the right skills, experience, and character. You’ll also need to check for things like past offences or conflicts of interest. If you outsource the role, you must choose someone based in Australia who can commit the time and meet all the new requirements.

Review your business structure and governance

If your business operates as a partnership, franchise, or group structure, you’ll need to work out who your “governing body” is and how you’ll manage compliance across the group. Franchisors, in particular, should think carefully before taking on liability for their franchisees under a shared AML/CTF policy. The rules around group structures are stricter and more clearly defined under the new regime.

Sanctions compliance is now part of your AML/CTF obligations

Under the new rules, AML/CTF programs must include sanctions compliance. Sanctions laws apply to all businesses and individuals in Australia, and the obligations can be broad and complex. Terms like “dealing with” or “assisting” someone under sanctions can cover a wide range of business activity — even indirectly. Make sure you understand your obligations and watch for guidance from the Australian Sanctions Office in the coming weeks.

Enrolling with AUSTRAC will require more detail

From 31 March 2026, new and existing reporting entities will need to give AUSTRAC more information when enrolling. This includes:

• Details about the services your business offers

• Beneficial ownership and company structure

• Directors’ and partners’ personal information

• Revenue and industry details

• Memberships in professional associations

If this information changes (e.g. a director moves house), you’ll need to notify AUSTRAC within 14 days. Now is a good time to build internal processes to manage those updates.

Customer due diligence will go deeper

Businesses will need to collect more information from customers, including governance documents and decision-maker details. You’ll also need to screen for domestic politically exposed persons (PEPs), including local government officials and their close associates — something many systems currently miss.

Risk triggers could require extra checks

Under the new rules, certain types of activity — like unusually large or complex transactions, or activity without a clear purpose — may automatically trigger enhanced due diligence. This could mean extra checks or steps for your team. If you rely on automated transaction monitoring, you’ll need to make sure those alerts line up with your risk assessment and compliance obligations.

Think carefully before joining a “reporting group”

If you’re thinking about forming or joining a reporting group under the new regime, make sure you understand the risks and responsibilities. These groups can help with shared policies, but they also come with shared liability. Make sure the structure fits your business.

Final thoughts: what should you do now?

The key message from the session was simple: start now. Even though the final guidance isn’t out yet, there’s plenty you can do to get ready:

• Map out who is responsible for AML/CTF in your business

• Review your internal governance and compliance structure

• Check whether you’ll need to enrol or re-enrol with AUSTRAC

• Think about how you’ll manage sanctions and customer due diligence

• Make sure your AML Compliance Officer meets the new standards

  
  

These reforms will impact many businesses — including those that haven’t had to comply with AML/CTF laws before. If you’re in real estate, legal, accounting, or other professional services, it’s time to get prepared.

If you’d like help understanding what the changes mean for your business, get in touch with our team — we’re here to support you through the transition.