White paper · LIQ-2026-AUSTRAC-01

AUSTRAC AML/CTF obligations: a compliance white paper.

Australia’s anti-money laundering rules changed in 2026, and they can now apply to accountants, lawyers, conveyancers, real estate agents and dealers in precious metals, stones and products when they provide a designated service. This paper explains who the rules cover, what a regulated business has to have in place, the reports and deadlines it has to meet, and the transition dates that run through to 2030.

It is written for boards, senior managers and AML/CTF compliance officers. Read it here page by page, or download the PDF. Each regulatory point in it is cited to AUSTRAC’s own material.

Download the PDF Read it on this page

PDF · 1.2 MB · 49 pages · Position as at 2 August 2026

01 · The paper

Read the paper.

Turn pages with the arrows, your arrow keys or a swipe. Full screen and Lights out make it easier to read; Escape brings you back.

  1. Page 1 of 49. Section 01, Purpose and scope.
  2. Page 2 of 49. Section 02, Basis of this paper.
  3. Page 3 of 49. Section 03, Executive summary.
  4. Page 4 of 49. Section 03, Executive summary, continued.
  5. Page 5 of 49. Section 04, How to use this paper.
  6. Page 6 of 49. Section 05, AUSTRAC and Australia’s AML/CTF framework.
  7. Page 7 of 49. Section 06, Who is regulated.
  8. Page 8 of 49. Section 07, Designated services and regulatory scope.
  9. Page 9 of 49. Section 08, Current core AML/CTF obligations.
  10. Page 10 of 49. Section 09, Risk-based compliance framework.
  11. Page 11 of 49. Section 10, AML/CTF programs.
  12. Page 12 of 49. Section 11, Governance and accountability.
  13. Page 13 of 49. Section 12, Customer identification and verification.
  14. Page 14 of 49. Section 13, Customer due diligence and ongoing monitoring.
  15. Page 15 of 49. Section 14, Regulatory reporting obligations.
  16. Page 16 of 49. Section 14, Regulatory reporting obligations, continued.
  17. Page 17 of 49. Section 15, Record-keeping and information management.
  18. Page 18 of 49. Section 16, Employees, training, review and assurance.
  19. Page 19 of 49. Section 17, AUSTRAC Online operational requirements.
  20. Page 20 of 49. Section 18, AML/CTF reforms.
  21. Page 21 of 49. Section 18, AML/CTF reforms, continued.
  22. Page 22 of 49. Section 19, Newly regulated entities.
  23. Page 23 of 49. Section 19, Newly regulated entities, continued.
  24. Page 24 of 49. Section 19, Newly regulated entities, continued.
  25. Page 25 of 49. Section 20, Transition and implementation arrangements.
  26. Page 26 of 49. Section 21, Industry-by-industry obligations.
  27. Page 27 of 49. Section 21, Industry-by-industry obligations, continued.
  28. Page 28 of 49. Section 21, Industry-by-industry obligations, continued.
  29. Page 29 of 49. Section 21, Industry-by-industry obligations, continued.
  30. Page 30 of 49. Section 22, Regulatory supervision and non-compliance.
  31. Page 31 of 49. Section 23, Education and compliance resources.
  32. Page 32 of 49. Section 24, Consultations and unresolved developments.
  33. Page 33 of 49. Section 25, Consolidated implementation checklist.
  34. Page 34 of 49. Section 25, Consolidated implementation checklist, continued.
  35. Page 35 of 49. Section 26, Key dates and transition timeline.
  36. Page 36 of 49. Section 27, Industry-obligation comparison matrix.
  37. Page 37 of 49. Section 27, Industry-obligation comparison matrix, continued.
  38. Page 38 of 49. Section 28, Glossary.
  39. Page 39 of 49. Section 29, Concluding observations.
  40. Page 40 of 49. Section 30, Citations.
  41. Page 41 of 49. Section 30, Citations, continued.
  42. Page 42 of 49. Section 30, Citations, continued.
  43. Page 43 of 49. Section 30, Citations, continued.
  44. Page 44 of 49. Section 30, Citations, continued.
  45. Page 45 of 49. Section 30, Citations, continued.
  46. Page 46 of 49. Section 30, Citations, continued.
  47. Page 47 of 49. Section 30, Citations, continued.
  48. Page 48 of 49. Section 30, Citations, continued.
  49. Page 49 of 49. Section 30, Citations, continued.

The PDF download is the accessible, searchable text of these pages. The paper states the position at 2 August 2026, so check the cited AUSTRAC material before relying on it.

02 · Contents

What the paper covers.

The paper’s 30 sections. Each one opens the reader at its first page.

Scope

  1. Purpose and scope , page 1
  2. Basis of this paper , page 2
  3. Executive summary , page 3
  4. How to use this paper , page 5
  5. AUSTRAC and Australia’s AML/CTF framework , page 6
  6. Who is regulated , page 7
  7. Designated services and regulatory scope , page 8

Core obligations

  1. Current core AML/CTF obligations , page 9
  2. Risk-based compliance framework , page 10
  3. AML/CTF programs , page 11
  4. Governance and accountability , page 12
  5. Customer identification and verification , page 13
  6. Customer due diligence and ongoing monitoring , page 14
  7. Regulatory reporting obligations , page 15
  8. Record-keeping and information management , page 17
  9. Employees, training, review and assurance , page 18
  10. AUSTRAC Online operational requirements , page 19

Reforms and transition

  1. AML/CTF reforms , page 20
  2. Newly regulated entities , page 22
  3. Transition and implementation arrangements , page 25

Industries and supervision

  1. Industry-by-industry obligations , page 26
  2. Regulatory supervision and non-compliance , page 30
  3. Education and compliance resources , page 31
  4. Consultations and unresolved developments , page 32

Working tools

  1. Consolidated implementation checklist , page 33
  2. Key dates and transition timeline , page 35
  3. Industry-obligation comparison matrix , page 36
  4. Glossary , page 38
  5. Concluding observations , page 39
  6. Citations , page 40

03 · Findings

Four points from the paper.

  1. Scope follows the service, not the industry.

    A person or organisation that provides a designated service with the required geographical link to Australia is a reporting entity. The service, the customer, the start point, the geographical link and any exception or exemption decide whether an obligation applies. An industry label points to likely exposure and decides nothing.

    Paper, pages 3 and 39

  2. The reformed obligations are in force.

    They commenced on 31 March 2026 for entities already regulated. Newly regulated professional, real estate and precious metals, stones and products services, together with specified new virtual asset services, commenced on 1 July 2026, subject to transitional rules.

    Paper, page 3

  3. A program should show it operates.

    An AML/CTF program is the documented ML/TF/PF risk assessment and the policies that manage those risks. The risk assessment, policies, customer risk ratings, monitoring, reporting, training and assurance processes should be connected, with records that show the decisions made and the actions taken.

    Paper, pages 11 and 39

  4. Transition dates run on separate clocks.

    Independent evaluation dates, the move from the former customer identification procedure, the IFTI to IVTS change and the reporting form changeovers follow different rules. Some depend on the enrolment date or the AUSTRAC Account Number, so each needs tracking on its own.

    Paper, page 39

04 · Deadlines

Recurring deadlines and thresholds.

From the paper’s consolidated table. Each deadline has its own trigger and exceptions, set out in sections 7, 10 and 14 to 16.

Recurring AML/CTF deadlines and thresholds, as stated in the white paper at 2 August 2026 (page 16).
Requirement Deadline or threshold Qualification
Enrolment No later than 28 days after the day the entity starts providing a designated service. Remittance and virtual asset service providers must also register.
Enrolment details Updated within 14 days after the relevant change. Additional information applies to remittance and virtual asset service providers.
Registration renewal Every three years. Remittance and virtual asset service providers.
Suspicious matter report 24 hours for terrorism financing. Three business days otherwise, or up to five for a qualifying report involving legal professional privilege. Time starts when reasonable grounds for suspicion are formed.
Threshold transaction report Physical currency of A$10,000 or more, reported within 10 business days. Applies to a qualifying designated-service transaction.
Precious metals, stones and products A$10,000 or more in physical currency or virtual assets, across one transaction or linked or apparently linked transactions. Sets the scope of the dealer’s designated service; the TTR has its own physical currency test.
International funds transfer instruction Within 10 business days. Continues until the entity’s IVTS transition date.
Cross-border movement A$10,000 or more: before customs or before sending, or within five business days after receipt. Physical monetary instruments, not electronic transfers. Applies even if unrelated to a designated service.
Annual compliance report Within three months after the financial year ends, in the 1 July to 30 September window. Subject to reporting entity and exemption rules.
Program update record Within 14 days after making an update. Applies to relevant risk assessment and policy changes.
Whole-program review At least once every three years, and earlier when triggered. Separate from independent evaluation.
Independent evaluation At least once every three years under the entity’s risk-based policy. Transitional dates can extend the first one.
Record retention Usually seven years. The start date differs for program, customer due diligence and transaction records.

Open the table on page 16.

05 · Key dates

From the 2024 Act to the last transition in 2030.

The paper’s timeline, with each status as the paper gave it at 2 August 2026, condensed.

  • Passed by 2 August 2026
  • Every year
  • Still to come

  1. Parliament passed the Amendment Bill.

    Enacted

  2. Financial Transaction Reports Act 1988 repealed. Residual confidentiality and record duties can continue.

    Current

  3. The reformed tipping-off offence commenced.

    In force

  4. AML/CTF Rules 2025 registered.

    In force, subject to amendment

  5. Reforms commenced for existing reporting entities, with the digital currency exchange to virtual asset service provider rollover and item 50A duties.

    In force

  6. Window for eligible existing entities to put transitional customer identification (ACIP) policies in place.

    Elapsed condition

  7. Newly regulated professional, real estate and precious metals, stones and products services commenced, with the deferred new virtual asset services.

    In force

  8. Transitional compliance officer notification and certain early virtual asset application deadlines.

    Elapsed

  9. 1 July to 30 September, each year

    Annual compliance report submission window for the preceding financial year.

    Current, where applicable

  10. An existing entity’s first reformed independent evaluation, where the transitional criteria apply.

    Transition

  11. Last day of the optional SMR and TTR form transition for entities enrolled on 30 March 2026.

    Transition

  12. The transitional ACIP arrangement ends for entities that qualified for it, IFTI reporting generally moves to IVTS, and the deferral for unverified self-hosted wallet reporting ends.

    Enacted, future

  13. Latest eligible substitute IVTS transition date.

    Conditional

  14. Staggered first independent evaluation deadlines for new and former item 54-only entities, set by the last two digits of the AUSTRAC Account Number.

    Transition

Open the timeline on page 35.

06 · Checklist

Implementation checklist.

The checklist LensIQ uses in its own implementation engagements, worked through in order. Tick an item once it is evidenced rather than asserted, and check each one against the cited AUSTRAC material and current legislation.

22 items

0 of 22
Scope and mobilisation 5
  • Read it on page 7
  • Read it on page 8
  • Read it on page 8
  • Read it on page 8
  • Read it on page 19
Governance and program 5
  • Read it on page 12
  • Read it on page 10
  • Read it on page 10
  • Read it on page 11
  • Read it on page 30
Customers and transactions 6
  • Read it on page 13
  • Read it on page 13
  • Read it on page 14
  • Read it on page 14
  • Read it on page 15
  • Read it on page 15
People, records and assurance 6
  • Read it on page 18
  • Read it on page 18
  • Read it on page 17
  • Read it on page 11
  • Read it on page 18
  • Read it on page 18

Section 25 of the paper, from page 33.

07 · Glossary

Terms and acronyms.

Every term from section 28 of the paper, plus six abbreviations defined elsewhere in it.

AAN AUSTRAC Account Number
Its last two digits set the first independent evaluation deadline for new and former item 54-only entities. Page 25
ACIP Applicable customer identification procedure
The customer identification procedure under the former framework. Entities enrolled on 30 March 2026 that had transitional policies in place by 1 July 2026 may use it for documented customer classes until 31 March 2029. Page 25
AML/CTF Anti-money laundering and counter-terrorism financing
AUSTRAC’s reformed materials also embed proliferation financing risk. Page 38
AUSTRAC Australian Transaction Reports and Analysis Centre
Australia’s AML/CTF regulator and financial intelligence unit. Page 38
AUSTRAC Online
The portal used for enrolment, registration, user and entity management, and regulatory reporting. Page 38
Beneficial owner
The natural person or people who ultimately own or control a customer that is not an individual, under the applicable tests. Page 38
CBM Cross-border movement
Movement of physical currency or other monetary instruments across Australia’s border. Page 38
CDD Customer due diligence
Initial, ongoing and enhanced measures, and simplified measures where permitted. Page 38
DCE Digital currency exchange
The older term for what is now a virtual asset service provider. Registered DCEs became VASPs on 31 March 2026. Page 25
Designated service
A regulated activity listed in section 6, tables 1 to 6, of the AML/CTF Act. Page 38
DPMSP Dealer in precious metals, stones and products
A business buying or selling covered items for physical currency or virtual assets at A$10,000 or more, including linked transactions. Page 22
Governing body
The highest-level body responsible for oversight and executive decisions. Page 38
IFTI International funds transfer instruction
Reporting under the preserved pre-reform regime, which continues until the entity’s IVTS transition date. Page 15
IVTS International value transfer service
Reformed international value transfer reporting, generally from 31 March 2029. Page 15
KYC Know your customer
Information about a customer, and its verification, undertaken through customer due diligence. Page 38
LPP Legal professional privilege
Protects qualifying information or documents, and must be claimed precisely. Page 38
ML/TF/PF Money laundering, terrorism financing and proliferation financing
The three risks an AML/CTF risk assessment must address. Page 10
PEP Politically exposed person
Certain PEP circumstances require additional customer due diligence. Page 38
REST Reporting Entity System Transformation
AUSTRAC’s program changing its interfaces and IFTI-E reporting features. Page 19
Reporting entity
A legal person providing a designated service with the required geographical link to Australia. Page 38
Reporting group
An arrangement under the Act and Rules through which related entities share specified compliance arrangements under a lead entity. Page 38
RSP / RNP Remittance service provider / remittance network provider
Remittance businesses, which must register with AUSTRAC as well as enrol. Page 8
SMR Suspicious matter report
Due within 24 hours for terrorism financing suspicions and three business days otherwise, or up to five for a qualifying report involving legal professional privilege. Page 15
TFS Targeted financial sanctions
Sanctions checks that are separate from PEP checks and apply before a service is provided. Page 14
Travel rule
Requirements to collect, keep and pass on information with specified value transfers. Page 38
TTR Threshold transaction report
A report of a qualifying physical currency transaction of A$10,000 or more. Page 38
VASP Virtual asset service provider
Replaces the older DCE term and covers expanded virtual asset services. Page 38
08 Questions

About the paper.

What date is the paper current to?

2 August 2026 (Australia/Sydney time). Later amendments, Rules, exemptions, AUSTRAC statements or system changes may affect the analysis, so check the cited AUSTRAC material before you rely on it.

Is this legal advice?

No. The paper explains AUSTRAC’s published obligations and guidance. The AML/CTF Act and Rules create the legal obligations and the courts decide their final interpretation. Questions of scope, exemption, privilege or cross-border structure need qualified legal advice.

Does it tell me whether my business is regulated?

It explains how scope is worked out: the service provided, the customer, the start point, the geographical link and any exception or exemption (sections 6 and 7), with what that means for each industry in section 21. For a first answer on the services newly regulated from 1 July 2026, use the Am I Regulated check on this site. Where scope remains uncertain, the paper recommends qualified legal advice.

Where are the sources?

Section 30, from page 40, lists 110 citations in order of first appearance. Each names the AUSTRAC page relied on, the date AUSTRAC last showed it as updated where that was displayed, and its address.

Find out where your business sits.

The Am I Regulated check works through AUSTRAC’s designated-service questions for the services newly regulated from 1 July 2026 and tells you whether you may be a reporting entity. It runs in your browser and keeps nothing.

Check if you are regulated Start your AML/CTF program