The AML/CTF changes LensIQ has tracked since the newly regulated sectors started on 1 July 2026, newest first. Most are AUSTRAC guidance rather than law, one is a Bill that is not law yet, and each entry is labelled accordingly. Each one ends with what to do about it.
Kept for accountants and bookkeepers, lawyers, conveyancers, real estate businesses, trust and company service providers and dealers in precious metals, stones and products.
Pick a sector to hide the entries that do not affect it. The label on each entry matters: a clarified reading of the Act is not new law, and a Bill is not law at all.
Schedule 7 of the Treasury Laws Amendment (Strengthening Accountability for Tax Adviser Misconduct and Other Measures) Act 2026, which received Royal Assent on 15 September, changed one term in section 39E from 1 October. The section concerns an exemption tied to a table 1 securities disposal service.
What to do Note it in the legislation register. An ordinary Tranche 2 program needs no change.
AUSTRAC began issuing infringement notices to businesses it believes did not enrol within 28 days of becoming reporting entities (for a business regulated from 1 July, generally by 29 July 2026). The first notices went to businesses in the real estate, accounting and jewellery sectors. It gave the amounts as $21,840 for a body corporate and $4,368 for an individual, said liability can keep accruing, and said about 90 per cent of the first group had since enrolled or tried to.
What to do If the business provides a designated service and is not enrolled, enrol now and record the gap as a compliance incident.
Source AUSTRAC, AUSTRAC begins issuing infringement notices to non-enrolled businesses, 30 September 2026
A suspicious matter report rests on reasonable grounds for suspicion, not proof of a crime, and it is due within 24 hours for terrorism financing and generally three business days otherwise. A threshold transaction report is about physical currency of A$10,000 or more: a card payment, cheque or electronic transfer is not one because of its size. The first compliance report covers 1 July 2026 to 30 June 2027.
What to do Check that TTR rules look for physical currency, and that staff know an SMR does not wait for proof.
Source AUSTRAC, How to get your reporting right, 30 September 2026
AUSTRAC changed its item 3 guidance to remove the suggestion that a business had to be a professional first. The test is conduct: receiving, holding and controlling, or managing, someone else’s money or property in a way that directly advances a transaction, in the course of business, outside the subsection 6(5C) exclusions. An accounting practice paying a client’s bills from its own account is likely in scope. A bookkeeper making set payroll, rent and tax payments with no real discretion is less likely to be managing the money. The incidental exclusion is judged across the whole business, so an address service elsewhere in the firm can stop it applying. AUSTRAC’s litigation example works the same way: settlement money a litigation practice holds may be excluded, but not if the same practice also does conveyancing.
What to do Redo the item 3 scope assessment on the conduct test, at the level of the legal entity.
Source AUSTRAC, Professional designated services (last updated 25 September 2026)
The Bill would let the AUSTRAC CEO restrict or prohibit a high-risk mechanism by legislative instrument, with cryptocurrency ATMs given as an example. It would also make technical amendments touching customer due diligence, politically exposed persons, legal professional privilege and international value transfer services. It was not law at 4 October 2026.
What to do Track it. Do not build it into policy until it passes and commences.
Source Parliament of Australia, Anti-Money Laundering and Counter-Terrorism Financing Amendment Bill 2026
Providing a registered office or principal place of business address starts when the address is made available for the customer’s use or intended use, which can be before it is lodged with ASIC. It applies whether or not a fee is charged, and to equivalent addresses overseas. An accounting firm that lets a company use its address as the registered office, while the company works from somewhere else, provides item 9.
What to do List every address service, including free and bundled ones, and complete initial customer due diligence before the address is made available, unless an exception applies.
AUSTRAC separated a leasehold interest from a standalone contractual licence to occupy. In AUSTRAC’s view a standalone licence that gives limited occupation rights and no interest in land is not, of itself, real estate for these services. In its retirement village example the resident is not on title and cannot sell, transfer or sublet, so the licence falls outside. What the agreement is called does not settle it; the rights it grants do.
What to do Add a tenure check at matter opening for retirement villages, long leases and other unusual occupation arrangements.
AUSTRAC added an example on notaries to its professional designated services guidance. It creates no separate notary obligation: the question is still whether the underlying work is a table 6 service.
What to do Classify notarial work by the service performed.
AUSTRAC began sending section 167 information notices to businesses that appeared to be providing designated services without enrolling. Recipients included real estate agents, accountants, lawyers and jewellers.
What to do Confirm that the legal entity providing each designated service is the one enrolled.
Source AUSTRAC, AUSTRAC issues notices to non-enrolled businesses, 28 August 2026
In the simplified verification material for bodies corporate, partnerships, unincorporated associations and government bodies, “a person receiving a service on the customer’s behalf” was corrected to “a person on whose behalf the customer is receiving a service”. They are different people.
What to do Search procedures, onboarding forms and vendor rules for the old wording and replace it.
Interventions will include newly regulated businesses that have not enrolled and businesses recklessly involved in, or complicit with, criminal activity. Suspicious matter report quality is a named priority, and AUSTRAC will engage with entities whose reports are consistently poor. It also plans to redesign the annual compliance report with industry.
What to do Be able to show the program operating: decisions recorded, reports reviewed for quality.
The politically exposed persons and source of funds and source of wealth pages show 29 July updates. AUSTRAC’s register of significant guidance changes does not list them, so read them as current guidance, not new obligations. In the specified circumstances they tie senior manager approval and source of funds and source of wealth work to foreign PEPs, and to domestic and international organisation PEPs where the customer is high risk.
What to do Check that the PEP process separates the categories and scales source of funds work to risk.
Customer due diligence, monitoring and reporting can be outsourced, but the reporting entity stays responsible and is generally liable for breaches. AUSTRAC expects due diligence on the provider and ongoing oversight, and recommends a written agreement and outsourcing procedures set out in the program.
What to do Review each AML/CTF provider: due diligence on file, contract terms, oversight and access to records.
Source AUSTRAC, Using outsourcing to help meet your obligations (last updated 13 July 2026)
Guidance for insolvency practitioners now links to information on enrolling in an individual capacity, for practitioners who provide designated services themselves rather than only through a firm.
What to do Map who provides each service, practitioner or firm, and enrol accordingly.
Source AUSTRAC, How designated services apply to insolvency practitioners
AUSTRAC’s privilege guidance now includes the forms and the process for making a claim to AUSTRAC. Privilege is claimed through that process; it is no blanket exemption from AML/CTF duties.
What to do Update escalation and SMR procedures to use the current claim process.
AUSTRAC expanded its guidance on pre-commencement customers. It looks at the actual business relationship: how recent it is and whether services are expected to continue. A name in an old matter file is not enough on its own.
What to do Re-test which legacy clients genuinely qualify, and record why.
New suspicious matter and threshold transaction report forms started. Entities enrolled after 30 March 2026 use them; some existing entities have transitional arrangements.
What to do Confirm AUSTRAC Online access and who in the business can lodge.
Grouped by when they need doing. The first group is either already due or follows directly from guidance that applies now.
Not sure whether a service you provide is designated? Check if you are regulated.
For the obligations themselves, the AML/CTF white paper sets out the position at 2 August 2026.
The first independent evaluation for a newly regulated business depends on the last two digits of its AUSTRAC Account Number.
| Last two digits of the AUSTRAC Account Number | Evaluation due by |
|---|---|
| Both odd | 30 June 2029 |
| Second-last odd, last even | 31 December 2029 |
| Both even | 30 June 2030 |
| Second-last even, last odd | 31 December 2030 |
Position as at . AUSTRAC updates its guidance often; check the current page before relying on any point here.