AML - Anti Money Laundering
DNA Chartered Accountants has been auditing, providing guidance and implementing AML standards for APRA regulated entities across Australia. Our compliance team at DNA Chartered Accountants assist in developing and maintaining an AML/CTF program tailored to your business as per AUSTRAC requirements. We have done this for banks, insurance companies and for other smaller businesses. Custom made implementation tool kit with documentation and AML checklists, AML risks and AML controls with AUSTRAC reporting triggers – all for 100% bullet proof compliance for your business.
DNA Chartered has been developing tailored tool kits for 100% compliance
New expanded scope includes…
From 1 July 2026, anti-money laundering and counter-terrorism financing (AML/CTF) obligations will apply to certain services typically provided by the following businesses:
- Real estate professionals – such as real estate agents, buyers’ agents and property developers
- Dealers in precious stones, metals and products
- Lawyers
- Conveyancers
- Accountants
- Trust and company service providers.
Additional virtual asset-related services will also come under AML/CTF regulation from 31 March 2026.
Both current and future reporting entities will need to prepare for new or changed obligations under the new AML/CTF laws.
This new AUSTRAC webpage summarises if you are new and your obligations.
If you are newly regulated under these changes, this page provides a summary of your key obligations.
AUSTRAC will develop guidance and educational materials to support new regulated entities to implement effective AML/CTF measures.
AUSTRAC will provide further guidance in 2025, including guidance on:
- the scope of the new regulated services
- core obligations and how they can be practically implemented.
Starter kits from AUSTRAC
AUSTRAC is also developing AML/CTF starter programs kits for small businesses in Tranche 2 sectors. The kits aim to increase the effectiveness of AML/CTF programs and will provide an AML/CTF program for a typical low complexity small business. They will reflect sector-wide money laundering, terrorism financing and proliferation financing risk and industry practice.
Guidance will be developed in close consultation with industry peak bodies and will be released for public consultation in mid-2025.
The key obligations for businesses regulated by AUSTRAC are:
- Enrol and register with AUSTRAC
- Develop and maintain an AML/CTF program tailored to your business
- Conduct initial and ongoing customer due diligence
- Report certain transactions and suspicious activities
- Make and keep records
In meeting AML/CTF obligations, the relevant laws also provide clear protections for information or documents that may be subject to legal professional privilege.
Understanding and meeting your AML/CTF obligations is essential to protect your business from misuse by criminals and ensure you comply with Australia’s AML/CTF laws.
Enrolling and registering with AUSTRAC
Your business must enrol with AUSTRAC within 28 days of providing a regulated service (known as a designated service) to avoid penalties. If you are a business that provides any of the newly regulated virtual asset services, these new laws will commence on 31 March 2026. This means you will have until 28 April 2026 to enrol.
If you are providing other newly regulated designated services, the new laws commence on 1 July 2026, and you must enrol by 29 July 2026.
DNA Chartered Accountants are also certified IT auditors and cyber security experts who can align your AML processes with CPS 234 requirements, thus bullet proofing your information security needs with AML compliance reporting triggers as per AUSTRAC guidance.
Registering obligations related to the new virtual asset services regulated by AUSTRAC commence from 31 March 2026. If your business provides one of these designated services, you must, in addition to enrolling, apply to register with AUSTRAC before 31 March 2026.
From 31 March 2026, you must not provide virtual asset-related designated services before AUSTRAC has confirmed your registration. Criminal penalties apply for non-compliance.
Report certain transactions and suspicious activity
Reporting certain transactions and suspicious activities maintains the integrity of the financial system and aids law enforcement in combating crime.
The types of reports you may need to submit to AUSTRAC are:
- Suspicious matter reports (SMR): When you suspect on reasonable grounds that a person is not who they claim to be or that a matter is linked to criminal activity or proceeds of crime.
- Threshold transaction reports (TTR): For individual physical currency transactions valued at A$10,000 or higher.
- International value transfer service reports (IVTS): For all international transfers of value transactions.
- Cross border movement reports: Submit when carrying physical currency or bearer negotiable instruments payable to bearer valued at A$10,000 or higher into or out of Australia.
- Annual compliance reports: Submit an annual report summarising how you have met your AML/CTF obligations in the previous year.
Record Keeping
You must make and maintain accurate and complete records for at least 7 years.
These records provide evidence of your due diligence, risk management practices and compliance with AML/CTF obligations. Your records include documents related to your:
- AML/CTF program
- customer due diligence
- transaction records
- staff training sessions
- audit results.
Clear protections for legal professional privilege
The new laws will provide clear protections for the disclosure of information or documents that may be subject to legal professional privilege.
The common law doctrine of legal professional privilege will remain unchanged under the reformed laws. This ensures that the AML/CTF Act does not require disclosure of any information or document that a person reasonably believes is subject to legal professional privilege.
The process for asserting privilege involves providing a dedicated legal professional privilege form in lieu of the requested information. This form will be available on the AUSTRAC website at a later date.
Further details on the process for managing and resolving assertions and claims of legal professional privilege will also be provided through Ministerial guidelines at a later date.
These changes come into effect on 1 July 2026. You can find out more in Schedule 4 to the AML/CTF Amendment Bill 2024.
Speak to Rhonda at 02 9064 4400 at DNA Chartered Accountants or email service@dnaca.com.au for a chat. We at DNA Chartered value early commencement for easy implementation.