AUSTRAC releases expectations on AML/CTF reform implementation. What Australian firms need to know

On 3 July 2025, AUSTRAC published a key update outlining what it expects from reporting entities in the lead up to major AML/CTF reforms.

With deadlines fast approaching, the announcement outlines what existing and newly regulated businesses need to do and when to prepare. Whether you're in financial services, law, real estate or accounting, this is a critical time to start planning. Here’s what you need to know.

Risk-based thinking over box-ticking 

AUSTRAC has acknowledged that the timeframes are tight. The 31 March and 1 July 2026 deadlines reflect Australia’s need to prepare for its upcoming FATF mutual evaluation.

While 100% compliance from day one isn’t expected, reporting entities must show genuine, risk-focused effort. That means creating AML/CTF programs tailored to your business and actual money laundering risks, not copying templates or building policies that look compliant on paper but lack substance.

AUSTRAC’s message is clear: focus on identifying, reducing and managing the real risks that apply to your business. Risk-based thinking should guide every decision.

Who needs to do what and by when

AUSTRAC has set different expectations for two groups: existing reporting entities and newly regulated businesses.

Existing reporting entities

If you're already regulated under the AML/CTF Act, you must comply with the new obligations from 31 March 2026.

AUSTRAC expects you to:

• Maintain and strengthen your current AML/CTF controls
• Develop an implementation plan for the reforms and track progress
• Prioritise updates that address your highest money laundering and terrorism financing risks

Newly regulated reporting entities

From 1 July 2026, businesses in the legal, accounting, real estate and high-value goods sectors (e.g. jewellers) will be brought into the AML/CTF regime for the first time.

AUSTRAC expects new reporting entities to:

• Enrol with AUSTRAC (enrolment opens 31 March 2026)
• Appoint a Compliance Officer
• Have an AML/CTF program in place
• Train your staff on your AML/CTF program and processes
• Be ready to start conducting customer due diligence and report any suspicious activity

What support is coming

To help businesses prepare, AUSTRAC will release several resources over the coming months, including:

• Regulatory priorities for 2025–26: an outline of AUSTRAC’s key areas of focus for its upcoming regulatory efforts (July 2025)
• Month-by-month implementation: a timeline detailing what AUSTRAC expects and when (July 2025)
• Starter AML/CTF programme: a template to help newly regulated sectors get started (December 2025)