The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 (Cth) (Act) is expected to reshape Australia’s financial crime landscape. If your organisation falls under the regime, the clock is ticking to become compliant—or risk serious consequences.
What's changing?
The Act introduces mandatory obligations for reporting entities to implement and maintain an anti-money laundering and counter-terrorism financing (AML/CTF) program. This includes implementing policies, procedures, systems, and controls that are tailored to the size and complexity of your organisation and aligned with AUSTRAC’s Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (No 1).
Who's affected and when?
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Tranche 1 Entities (who are already regulated under the AML/CTF regime) must have fully updated and compliant AML/CTF programs in place by 31 March 2026.
This includes conducting a fresh risk assessment, implementing a risk-based AML/CTF policy, and ensuring senior management oversight in line with the new legislative requirements.
- Tranche 2 Entities (newly regulated) must comply by 1 July 2026. These entities include:
- Real estate professionals;
- Dealers in precious metals and stones;
- Lawyers, conveyancers, accountants; and
- Trust and company service providers.
- All additional virtual asset-related services will also come under AML/CTF regulation and must comply by 31 March 2026.
Implementing a tailored AML/CTF program
In addition to maintaining their enrolment with AUSTRAC, newly regulated entities must assess their exposure to money laundering and terrorism financing risks, and implement a tailored AML/CTF program that includes customer due diligence, transaction monitoring, suspicious matter reporting, and record-keeping.
Let's get you ready
Russell Kennedy’s Corporate and Commercial team is here to help. We’ll keep you informed as the rules evolve and work with you to build a compliant and effective AML/CTF framework tailored to your business.
Contact Andrew Parlour, Jonathan Teh or a member of the Corporate and Commercial Advisory team for further advice.