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Reporting groups under Australia’s AML/CTF Rules 2025
Businesses can share one AML/CTF program instead of running their own by forming a reporting group. There are two types:
- Business groups – related companies under common control.
- Elected groups – unrelated firms that choose to partner up.
Each group must appoint a lead entity to manage compliance, reporting, and oversight. Reporting groups help cut duplication, pool resources, and simplify AML/CTF obligations.
2-1 Reporting group that is a business group
If your company has subsidiaries or is part of a larger corporate family, you can all share one AML/CTF program instead of running separate ones.
Conditions on group members
- Get everyone to agree in writing on which company will be the lead entity
- Make sure your chosen lead entity meets all the requirements (see below)
Lead entity requirements
The lead entity must:
- Have a formal written agreement from all other group members.
- Not be controlled by another group member who provides regulated financial or professional services under AML/CTF law.
- Have real decision-making power over AML/CTF policies for the whole group.
- Be one of the following:
- Australian company
- Registered foreign company (under the Corporations Act 2001)
- Trust with at least one Australian resident trustee
- Australian resident individual
2-2 Reporting group formed by election
Completely separate businesses can choose to form a reporting group and share a joint AML/CTF program. Think of it as a compliance alliance.
Conditions on group members
Each member must be one of the following:
- A reporting entity (a business that provides services regulated under AML/CTF law).
- A person responsible for meeting AML/CTF obligations on behalf of reporting group members.
- A member of a business group.
Special rule for business groups
If one member of a business group joins by election, then all members of that business group must also join. If one member leaves later, all members of that business group are automatically considered to have left, too. This is a package deal - they all come in together and they all leave together.
Lead entity requirements
The lead entity must:
- Not be controlled by another group member who provides regulated financial or professional services under AML/CTF law.
- If the reporting group includes one or more business groups, the lead entity must also belong to one of those business groups.
- Have real decision-making power over AML/CTF policies for the whole group.
- Be one of the following:
- A company incorporated in Australia.
- A registered foreign company under the Corporations Act 2001.
- A trust with at least one trustee who lives in Australia.
- An Australian resident (if not a company, foreign company, or trust).
Rules for joining a reporting group
- Get permission: New members need consent from the lead entity
- Update AUSTRAC: Reporting entities must update their enrollment details when membership changes
- Follow the process: The lead entity's policies must explain how membership changes are recorded
- Collective entry: In a business group, one member can make the election to join on behalf of all members, as long as all members consent.
- Automatic membership: If a new business joins a business group that's already in a reporting group, they automatically become part of the reporting group too.
Rules for leaving a reporting group
- Give notice: Members wanting to leave must give written notice to the lead entity.
- Lead entity exit: If the lead entity wants to leave, they must notify all other members in writing.
- Collective exit: If one member of a business group leaves, the entire business group is out.
Requirement to always have a lead entity
- A reporting group cannot operate without a lead entity for more than 28 days.
- During this time, each member that is a reporting entity must still follow the AML/CTF policies of the previous lead entity.
Membership of multiple groups
If you belong to both an elected reporting group and a business group that is also a reporting group, the law treats you as a member of the elected reporting group. The elected group takes precedence.
2-3 Conditions for discharging (carrying out) obligations
Members of a reporting group can fulfil AML/CTF obligations on behalf of other members within the same reporting group. A lead entity must be in place for this to work.
2-4 Conditions when a non-reporting entity discharges (carries out) obligations
When a group member that isn't technically a "reporting entity" handles obligations for other members, specific conditions must be met:
- The non-reporting member (“discharging member”) must conduct staff due diligence (background checks and suitability assessments) and provide training to carry out AML/CTF activities.
- Background checks and training must meet the standards of the reporting entity for which the AML/CTF obligations are being carried out.
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