Australia’s AML/CTF framework is going through the biggest expansion in its history. The penalties for getting not complying is not a stern letter — it’s a regulator with serious enforcement appetite and civil penalties that run into the tens of millions of dollars.
Our AML/CTF lawyers advise reporting entities on what the reformed AML/CTF regime actually requires; enrolment, risk assessment, an AML/CTF program that works in practice, customer due diligence, reporting and AUSTRAC engagement. Real, commercial compliance you can stand behind, without it dragging on for six months and three retainers.
Why 2026 Is the Year Australian AML/CTF Law Changed for Good
The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 (Cth) received Royal Assent on 10 December 2024 and rewrote the regime in two waves:
From 31 March 2026, the reformed rules commenced for existing reporting entities, and the AML/CTF regime expanded to capture every Virtual Asset Service Provider (VASP), not just fiat-to-crypto exchanges. Enrolment also opened for the newly captured sectors.
From 1 July 2026, “Tranche 2” obligations commence for an estimated 90,000+ new reporting entities: lawyers, conveyancers, accountants, real estate professionals, property developers, dealers in precious metals and stones, and trust and company service providers, wherever they provide a “designated service”. Tranche 2 entities can enrol with AUSTRAC from 31 March 2026 and must enrol by 29 July 2026.
The result: a much larger universe of businesses now face genuine AML/CTF obligations, a regulator (AUSTRAC) that has shown real appetite for enforcement in the gambling and digital-asset sectors, and a compliance bar that a downloaded template will not clear. This is what we help our clients navigate.
Who We Help
Our AML/CTF practice serves the businesses most affected by the reforms.
Clubs, pubs and gaming venues working through their obligations as providers of gambling designated services — including the customer due diligence questions that cashless and account-based gaming, member cards and player accounts now raise.
Crypto exchanges and digital asset businesses (VASPs) dealing with AUSTRAC enrolment, transaction monitoring, the travel rule and the dual AML/CTF and financial-services obligations the 2026 reforms created. (See our cryptocurrency and digital assets services.)
Professional services firms newly in scope from 1 July 2026 — lawyers, accountants, conveyancers, real estate agents, property developers and trust and company service providers that need a compliance framework built from scratch, fast, and one that works alongside their other obligations rather than against them.
Existing reporting entities in financial services, remittance and lending updating their programs, risk assessments and customer due diligence to the reformed 2026 standard.
Our AML/CTF Services
AUSTRAC Enrolment and Registration
We handle enrolment end-to-end, work out exactly which of your services are “designated services” that bring you into the regime, and manage the registration steps and deadlines, including the 29 July 2026 enrolment cut-off for newly regulated entities.
AML/CTF Programs and Risk Assessments
The reforms replaced the old structure with a single AML/CTF program built on a genuine, business-wide money-laundering and terrorism-financing risk assessment. We design programs your team will actually use, including risk assessment, AML/CTF policies, governance, and the systems and controls that sit behind them instead of a binder that collects dust in the filing cabinet drawer.
Customer Due Diligence (CDD/KYC)
We design proportionate customer due diligence, initial and ongoing, simplified and enhanced, that meets the reformed standard without grinding your customer experience to a halt. This is where most reporting entities get the balance wrong.
Reporting, Monitoring and Compliance Officers
We advise on suspicious matter reports, threshold transaction reports and value-transfer reporting, transaction-monitoring obligations, and the appointment of an AML/CTF compliance officer at management level a specific requirement under the reforms.
Independent Review, Training and Remediation
We support the independent evaluation of your program, board and staff training, and remediation where a gap, a notice or an incident has already surfaced — including engagement with AUSTRAC.
A Focus on Clubs and Gaming Venues
Gaming venues sit in a sector AUSTRAC watches closely, and the reforms intersect awkwardly with how clubs actually operate.
We help community clubs and venues work through the practical questions the rules don’t answer cleanly, including when a member or loyalty card crosses into a regulated player account, what customer due diligence applies as cashless and account-based gaming rolls out, and the common misconceptions that leave boards exposed.
It’s advice grounded in how a club actually runs, not a generic checklist.
Why a Specialist AML/CTF Lawyer Matters
The exposure is not theoretical. Civil penalties under the AML/CTF Act reach into the tens of millions of dollars per contravention (up to $33 million for a body corporate) and AUSTRAC has demonstrated, in the gambling and casino sectors in particular, that it will pursue large matters to judgment. For the professions joining the regime in 2026, there is the added complexity of doing all of this for the first time, on a tight deadline, while preserving things like legal professional privilege.
Generic advice, or a template downloaded and tweaked, does not survive contact with this regulatory environment. Specialist advice at the right moment changes the trajectory of a matter; the wrong advice, or no advice, can end one.
How We Work
Commercial. Compliance has to be operationally workable. A program your team can’t follow is a program a regulator will find a gap in.
Technically literate. We understand the systems behind the obligations — gaming and payment platforms, exchange and wallet architecture, transaction-monitoring tooling so the advice reflects how your business actually operates.
Direct. Where the law is clear, we say so. Where it’s ambiguous, we tell you the range and our recommended position. We don’t pile on caveats to make our advice unfalsifiable.
Responsive. The deadlines don’t move. When you need an enrolment lodged, a program delivered or an AUSTRAC response drafted, we move at the speed the matter demands.
Frequently Asked Questions
Who has to comply with the AML/CTF regime in Australia?
Any business that provides a “designated service” with an Australian link is a reporting entity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth). That has traditionally meant banks, remitters, lenders and gambling operators and, since the 2024 reforms, every virtual asset service provider, and from 1 July 2026 a wide range of professional services. Whether you’re caught depends on the specific services you provide, which is the first thing we assess.
What are the Tranche 2 reforms and who do they affect?
Tranche 2 extends the AML/CTF regime to around 90,000 new reporting entities — lawyers, conveyancers, accountants, real estate professionals, property developers, dealers in precious metals and stones, and trust and company service providers — where they provide designated services. Obligations commence on 1 July 2026, with AUSTRAC enrolment open from 31 March 2026 and required by 29 July 2026.
When do the AML/CTF reforms commence?
The reformed rules commenced for existing reporting entities and for virtual asset service providers on 31 March 2026. Tranche 2 entities can enrol with AUSTRAC from 31 March 2026, must enrol by 29 July 2026, and are subject to full obligations from 1 July 2026.
Do clubs and gaming venues have AML/CTF obligations?
Yes. Gambling services are designated services, so clubs, pubs and other venues that provide them are reporting entities. The reforms raise practical questions for the sector — particularly around customer due diligence as cashless and account-based gaming expands, and where a member or loyalty card crosses into a regulated player account. We help venues work through these in a way that fits how a club actually operates.
What must an AML/CTF program include?
Under the reformed regime, a reporting entity needs a single AML/CTF program built on a business-wide risk assessment, with AML/CTF policies, governance, customer due diligence, transaction monitoring and reporting, an AML/CTF compliance officer at management level, ongoing training, and independent review. The program has to be proportionate to your actual risk and genuinely operational, not just documented.
What are the penalties for breaching the AML/CTF Act?
Civil penalties reach into the tens of millions of dollars per contravention and up to $33 million for a body corporate – alongside enforceable undertakings, remedial directions and reputational damage. AUSTRAC has pursued major matters in the gambling and casino sectors, and has been clear about its appetite for action against entities that fail to comply.
Do lawyers and accountants really need to register with AUSTRAC?
If they provide designated services, yes. From 1 July 2026 many legal, accounting, conveyancing and real estate practices are reporting entities and must enrol with AUSTRAC (enrolment open from 31 March 2026 and required by 29 July 2026), implement an AML/CTF program and appoint a compliance officer. The reforms include provisions to preserve legal professional privilege, but they do not remove the obligation to comply.
The deadlines are close and AUSTRAC is watching. Book a confidential AML/CTF readiness review with our team. We’ll tell you whether you’re in scope, what you need to have in place and by when, and the fastest compliant path to get there – no padded scopes, no fear-selling. Speak to an AML/CTF lawyer or call +61 7 5575 8011.
For more on related areas of our practice, see our pages on cryptocurrency and digital assets and privacy and data. For official guidance, see AUSTRAC and the Department of Home Affairs’ overview of the AML/CTF Amendment Act.
TechLawyers.com.au is operated by Rubicon Law and advises clients in Brisbane, the Gold Coast, Sydney, Melbourne, Perth and across Australia.
This page is general information about Australian AML/CTF law and is not legal advice. The information is current as at June 2026. For advice on your specific circumstances, please contact us directly.