AML/CTF Compliance for Your Business

Does your business fall under AUSTRAC regulations? Existing reporting entities moved to the reformed obligations on 31 March 2026, and newly regulated Tranche 2 businesses have been regulated since 1 July 2026.

In short

Your business is an AUSTRAC reporting entity if it provides any designated service listed in the AML/CTF Act: banking, lending, remittance, digital currency exchange, gambling, and, since 1 July 2026, real estate, conveyancing, legal and accounting services, trust and company services, and dealing in precious metals and stones. If you do, you must enrol, run an AML/CTF program and report.

Many businesses are now subject to Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) regulations in Australia. If your business provides certain financial services, handles large cash transactions, or operates in regulated industries, you may be classified as a reporting entity under AUSTRAC.

Existing reporting entities have operated under the reformed obligations since 31 March 2026, and the newly regulated Tranche 2 sectors (real estate agents, lawyers, conveyancers, accountants and dealers in precious metals and stones) have been regulated since 1 July 2026, so now is the time to ensure your business is compliant.

Is Your Business a Reporting Entity?

Many business owners don't realize they're subject to AML/CTF regulations until it's too late. The penalties for non-compliance can be severe - including hefty fines, criminal charges, and reputational damage that can destroy your business.

Don't wait until AUSTRAC comes knocking. Proactive compliance is always better than reactive damage control.

Which Businesses Need AML/CTF Compliance?

Your business may be a reporting entity if you provide services in:

Casinos and gaming operations
Bullion dealers and precious metals
Financial services and institutions
Insurance and superannuation
Trust and company service providers
High-value goods dealers (art, jewelry, etc.)
Alternative payment platforms
Cash-intensive businesses

Note: This is not an exhaustive list. If your business handles significant cash transactions, facilitates international transfers, or provides financial advisory services, you may have AML/CTF obligations.

What does AML/CTF compliance mean for your business?

Compliance with AML/CTF laws isn't just about ticking boxes - it's about implementing a comprehensive program that protects your business from being exploited by criminals for money laundering or terrorism financing.

The first critical step is conducting a thorough ML/TF Risk Assessment specific to your business operations, customer base, and service offerings. This assessment forms the foundation of your entire AML/CTF Program.

What are the core AML/CTF program requirements?

Know Your Customer

Verify customer identities and understand their business relationships with you

Risk Assessment

Identify and evaluate money laundering and terrorism financing risks in your business

Written Policies

Document comprehensive procedures and controls to mitigate identified risks

Transaction Monitoring

Ongoing monitoring for suspicious activities and threshold transactions requiring reporting

Record Keeping

Maintain detailed records of all transactions and verifications for at least 7 years

Staff Training

Regular training to ensure all staff understand their AML/CTF obligations and responsibilities

What do you have to report to AUSTRAC?

Threshold Transaction Reports (TTRs)

Required for physical cash transactions of AUD $10,000 or more. These must be reported to AUSTRAC within 10 business days.

Suspicious Matter Reports (SMRs)

Must be submitted within 24 hours for attempted transactions and 3 business days for completed transactions when you have reasonable grounds to suspect money laundering or terrorism financing. Includes both successful and attempted suspicious transactions.

International Funds Transfer Instructions (IFTIs)

Required if your business sends or receives international wire transfers. Must include complete payer and recipient information.

What happens if you don't comply?

Failing to meet your AML/CTF obligations can result in:

  • Civil penalties up to $22 million for corporations and $4.4 million for individuals
  • Criminal prosecution with potential imprisonment for serious breaches
  • Reputational damage that can destroy customer trust and business relationships
  • Loss of business licenses and inability to operate in regulated industries
  • Increased scrutiny from regulators and law enforcement

How can SNS Accounting help your business comply?

We understand that AML/CTF compliance can seem overwhelming, especially if you're not sure whether your business is even a reporting entity. That's where we come in. Our team of AML experts has helped hundreds of businesses across diverse industries achieve and maintain compliance with AUSTRAC regulations.

We've worked with businesses in:

Payment services
Gaming and entertainment
High-value goods retail
Financial advisory
Import/Export businesses
And many more...

Our comprehensive services include:

  • Initial assessment to determine if your business is a reporting entity
  • Comprehensive ML/TF Risk Assessment tailored to your business
  • Development of customized AML/CTF Programs
  • Implementation of customer verification procedures
  • AUSTRAC registration and reporting setup
  • Staff training programs on AML/CTF compliance
  • Independent Reviews of your AML/CTF Program
  • Ongoing compliance support and monitoring
  • Representation and defense if AUSTRAC contacts your business

Don't Leave Your Business Exposed

Get expert guidance on your AML/CTF obligations. Start with a free assessment to determine if your business needs to comply.

Get Your Free AML/CTF Assessment

Good to know

Am I a reporting entity? Common questions

How to tell whether AML/CTF laws apply to your business, and what to do if they do.

How do I find out whether my business must comply with AML/CTF laws?

Work through the designated services in section 6 of the AML/CTF Act and the Tranche 2 additions. The test is the service you provide, not your industry label: a car dealer that also lends money, a travel agent that remits funds, or a business that sets up companies for clients can each be captured. AUSTRAC publishes a self-assessment guide, and we can confirm your position in a short scoping session.

Which businesses were added by the Tranche 2 reforms?

Real estate agents and property developers selling real estate, conveyancers, lawyers and accountants providing certain transactional services, trust and company service providers, and dealers in precious metals and stones. Obligations for these sectors commenced on 1 July 2026, with enrolment windows and transitional guidance published by AUSTRAC. Existing sectors such as remitters and digital currency exchanges moved to the amended rules from 31 March 2026.

What are the core obligations once I am a reporting entity?

Enrol with AUSTRAC within 28 days of first providing a designated service; complete a money-laundering and terrorism-financing risk assessment; adopt AML/CTF policies approved by a senior manager and overseen by your governing body; appoint an AML/CTF compliance officer; identify and verify customers and beneficial owners; monitor transactions; report suspicious matters, threshold cash transactions and, where relevant, international transfers; train staff; keep records for seven years; and have the program independently reviewed.

How much does AML/CTF compliance cost a small business?

Enrolment with AUSTRAC is free. The real costs are the initial risk assessment and program, staff time for customer checks, any identity-verification software, and periodic independent reviews. For a small firm with straightforward services this is typically a fixed one-off fee for setup plus a modest annual review. We quote in advance so you can budget for it.

What happens if I ignore my AML/CTF obligations?

AUSTRAC uses risk-based supervision, which means small businesses in newly regulated sectors are contacted, assessed and, where needed, directed to fix problems. Persistent or serious breaches attract infringement notices, enforceable undertakings and civil penalty proceedings, and providing a designated service while unenrolled is itself an offence. Banks also ask their business customers about AML/CTF status and can close accounts over concerns.

Can SNS Accounting handle AML/CTF compliance alongside our accounting?

Yes. We scope whether you are captured, enrol you, write the risk assessment and policies, set up customer due diligence and reporting procedures, train your team and arrange independent reviews, while continuing to look after your tax, BAS, bookkeeping and payroll. Because we are ourselves a Tranche 2 reporting entity, we run the same program internally. This page is general information, not legal advice.