Australia’s anti-money laundering and counter-terrorism financing (AML/CTF) framework has entered a new phase, with significant reforms now extending obligations to a broader range of businesses and professional services.

The reforms were introduced through the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act. The existing Act remains the principal legislation, but the regime has now been expanded and modernised.

For many businesses, the key change is that Australia’s AML/CTF regime now captures additional high-risk services. This includes services commonly provided by real estate professionals, lawyers, conveyancers, accountants, trust and company service providers, dealers in precious metals and stones, and certain virtual asset service providers. 

The purpose of the reforms is to make it harder for legitimate business structures, professional services, property transactions and high-value goods to be misused to move, hide or disguise the proceeds of crime. 

Who may be affected? 

A business is not automatically regulated simply because it operates in one of the affected industries. 

The key question is whether the business provides a regulated designated service with a geographical link to Australia. If it does, the business may become a reporting entity and be required to comply with AUSTRAC obligations. 

This means businesses should assess the actual services they provide, not just their industry label. 

As part of the amendments, designated services now include: 

• assisting in the planning or execution of a transaction to sell, buy or transfer real estate;
• receiving, holding, controlling or managing a person’s property to help in the planning or execution of a transaction;
• selling or transferring a shelf company;
• assisting in the planning or execution of the creation or restructuring of a body corporate or legal arrangement; and
• providing a registered office address or principal place of business address of a body corporate or legal arrangement.

For example, an accounting, legal, real estate or conveyancing business should not assume it is captured in every circumstance. Equally, it should not assume it is outside the regime without checking the specific services it provides. 

Key date for newly regulated businesses 

From 1 July 2026, newly regulated businesses providing captured designated services are required to comply with AML/CTF obligations. Newly regulated businesses must apply to enrol with AUSTRAC by 29 July 2026. 

Most newly regulated businesses will only need to enrol. However, businesses providing remittance or virtual asset designated services may also need to apply for registration. 

What do businesses need to do? 

If a business is captured, compliance is not just a form or one-off registration step. 

At a high level, regulated businesses may need to: 

• enrol with AUSTRAC; 
• appoint an AML/CTF compliance officer; 
• develop and maintain an AML/CTF program; 
• assess money laundering, terrorism financing and proliferation financing risk; 
• conduct customer due diligence; 
• monitor customer activity and transactions; 
• train relevant staff; 
• report certain matters to AUSTRAC; and 
• keep required records. 

The AML/CTF program is central. It should set out how the business identifies, assesses and manages financial crime risk in practice. It should also reflect the size, nature and risk profile of the business. 

A smaller business with a straightforward client base may not need the same level of complexity as a larger business dealing with high-value transactions, complex ownership structures, overseas clients, trusts or unusual payment arrangements. However, it still needs a defensible process. 

The $10,000 reporting obligation 

One key reporting obligation is the Threshold Transaction Report. 

A reporting entity must submit a Threshold Transaction Report to AUSTRAC where it provides a designated service involving the transfer of $10,000 or more in physical currency. This includes cash, such as banknotes and coins, and also applies to foreign currency of equivalent value. 

This is an important distinction. The obligation is not triggered simply because an invoice, contract or transaction is worth $10,000 or more. For threshold transaction reporting, the relevant trigger is $10,000 or more in physical currency in connection with the provision of a designated service. 

Businesses should ensure relevant staff understand this distinction, particularly those involved in client payments, trust accounts, settlements, accounts administration, high-value goods, customer onboarding or payment processing. 

Other reporting obligations

Depending on the business and the activity involved, reporting obligations may also include: 

• suspicious matter reports; 
• international funds transfer instruction reports; 
• cross-border movement reports; and 
• annual compliance reports. 

Suspicious matter reporting is particularly important. If a business forms a relevant suspicion, it may need to report that matter to AUSTRAC within strict timeframes. This means businesses need a clear internal escalation process, so staff know what to do if they identify unusual behaviour, inconsistent information, unexplained funds, complex structures or other red flags. 

Why this matters for employers 

For affected businesses, AML/CTF compliance has practical workforce implications. 

The reforms may require changes to: 

• client onboarding;
• identity verification;
• payment handling;
• internal approval processes;
• record keeping;
• staff training;
• role responsibilities;
• escalation pathways; and 
• compliance oversight.

A policy sitting in a folder will not be enough. Staff need to understand when due diligence is required, what information must be collected, when a matter should be escalated, and who is responsible for reporting.

This is particularly relevant for employees involved in finance, accounts, trust accounting, property transactions, settlements, customer intake, client administration, compliance, management or high-value sales. 

What should businesses do now? 

Businesses that may be affected should take the following steps now: 

1. Map the services provided – Identify whether the business provides any designated services under the AML/CTF regime. 
2. Confirm whether AUSTRAC enrolment is required – If the business provides captured designated services, confirm enrolment obligations and any registration requirements. 
3. Appoint responsibility internally – Identify who will be responsible for AML/CTF compliance and ensure they have enough authority and oversight to perform that role properly. 
4. Develop an AML/CTF program – Prepare a risk-based program that reflects the business, its customers, its services and its exposure to financial crime risk. 
5. Update operational processes – Review onboarding, identity verification, payment processes, file management, reporting pathways and record keeping. 
6. Train relevant staff – Ensure employees understand the practical requirements that apply to their role, including what to do if they identify a red flag. 
7. Keep records – Maintain clear records of customer due diligence, transactions, risk assessments, reports and compliance steps. 
8. Seek advice where unclear – Businesses dealing with complex structures, trusts, companies, foreign clients, high-value transactions or unusual payment arrangements should seek professional advice on whether the regime applies and what controls are required. 

Final point 

The AML/CTF reforms are a significant compliance development for many Australian businesses. The immediate priority is to determine whether the business is captured. If it is, the business should ensure it is enrolled with AUSTRAC, has a practical AML/CTF program, trains relevant staff, understands its reporting obligations and keeps appropriate records. 

For Queensland businesses, this is a timely reminder that financial crime compliance is now a mainstream governance issue. The businesses best placed to manage the change will be those that act early, document their assessment and build compliance into ordinary business systems.

Online training is available 

As part of the changes, Business Chamber Queensland is offering online training in AML/CTF directed both towards both existing and new reporting entities. This training will aid employers in their obligation to provide AML training to their employees. For more information and to discuss training options suited to your business needs, reach out to our Workplace Relations team.