AML Checklist & Guide
Australia — New Reporting Entities
Preparing Your Business for
New AML/CTF Obligations
Australia's Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) framework is expanding to include additional industries. If your business provides designated services and is not currently regulated by AUSTRAC, you may be considered a new reporting entity.
This guide outlines the key obligations your business may need to meet and provides a practical checklist to help you prepare for the introduction of the updated requirements on 1 July 2026.
⏰ Obligations effective: 1 July 2026 | Enrolment deadline: 29 July 2026
1
Newly regulated Tranche 2 entities must enrol with AUSTRAC by 29 July 2026. Registration is expected to open on 31 March 2026.
Tip: Enrolling early will allow your business time to implement the required AML/CTF framework before the compliance deadlines.
2
Your business must develop and maintain an AML/CTF Program that outlines how you will manage and reduce the risks of money laundering, terrorism financing and proliferation financing.
An effective program should:
- Identify and assess ML/TF/PF risks relevant to your business
- Include policies, procedures, systems and controls to manage these risks
- Be appropriate for the size, nature and complexity of your business
- Be documented and approved by a senior manager
- Be reviewed and updated as your business or risk environment changes
- Be independently reviewed at least every three years
- Include the appointment of a fit and proper AML/CTF Compliance Officer
Note: If you operate as a sole trader, you may undertake the role of Compliance Officer yourself.
3
Customer Due Diligence ensures you understand who your clients are and the level of risk they may pose.
CDD requirements generally include:
- Initial CDD — Verifying a customer's identity before providing designated services.
- Ongoing CDD — Monitoring the customer relationship and keeping information up to date.
- Enhanced CDD — Applying additional checks for higher-risk customers.
- Simplified CDD — Applying reduced checks where permitted under AML/CTF Rules.
As part of this process, you must determine whether the customer or related parties are:
- Who they claim to be
- Subject to financial sanctions
- A politically exposed person (PEP)
- A close associate or relative of a PEP
4
Reporting entities may be required to submit certain reports to AUSTRAC. Common reporting obligations include:
- Suspicious Matter Reports (SMR) — when a suspicious activity is identified
- Threshold Transaction Reports (TTR) — for cash transactions of AUD $10,000 or more
- International Value Transfer Service Reports (IVTS) — for international transfers of value
- Cross-Border Movement Reports — when physical currency of $10,000 or more enters or leaves Australia
- Annual Compliance Reports — summarising how AML/CTF obligations were met
5
Reporting entities must keep accurate records for at least seven years. These records demonstrate your compliance and may include:
- AML/CTF program documentation
- Customer due diligence records
- Transaction records
- Staff training records
- Suspicious activity records
- Independent review or audit results
Progress
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1. Industry Coverage
✓
My business provides designated services (accounting, financial services, legal, or trust & company services)
2. AUSTRAC Enrolment
✓
Enrolled with AUSTRAC before 29 July 2026
3 & 4. Risk Assessment
✓
ML/TF/PF risks identified and assessed (customer types, service delivery, jurisdiction)
✓
Inherent and residual risk documented
5. AML/CTF Program
✓
Documented AML/CTF program approved by senior management
6. Initial CDD
✓
Customer, beneficial owner and/or agent identified
✓
ML/TF/PF risk assessed at start of relationship
✓
PEP check conducted
✓
Sanctions screening conducted
7. Ongoing CDD
✓
Transactions monitored for suspicious activity
✓
Client information updated when necessary
✓
Risk profiles adjusted on trigger events
8. AML Compliance Officer
✓
AMLCO is an Australian resident and meets fit and proper person requirements
9 & 10. Record-Keeping
✓
Records maintained for CDD, risk assessments, and AML/CTF compliance
✓
Core records in place: AML/CTF program, CDD, transactions, training, independent reviews, suspicious activity reports
11. Reporting Obligations
✓
Applicable reports identified: SMR, TTR, Annual Compliance Reports
Tip: Switch to the Full Version above for the complete checklist with all sub-items and examples.
Progress
0 / 0 items
1. Determine Whether Your Industry Is Covered
Which of the following applies to your business?
✓
Accountants
✓
Financial service providers
✓
Lawyers
✓
Trust and company service providers
If you selected any of the above, your business may have obligations under the AML/CTF legislation.
2. AUSTRAC Enrolment
Have you enrolled your business with AUSTRAC?
✓
Yes — enrolled with AUSTRAC
✓
No — enrolment is required before 29 July 2026
3. Risk Assessment
Have you identified and assessed the ML/TF/PF risks relevant to your business? Consider:
Customer Type
✓
Individuals
✓
Companies
✓
Partnerships
✓
Trusts
Service Delivery
✓
Online
✓
In-person
Jurisdiction
✓
Domestic (Australia)
✓
International
4. Risk Evaluation
Have you assessed and documented:
- • Inherent risk (before controls)
- • Residual risk (after controls are applied)
✓
Yes — inherent and residual risk assessed and documented
✓
No — further action required
5. AML/CTF Program
Have you developed a documented AML/CTF program approved by senior management?
✓
Yes
✓
No — further action required
6. Initial Customer Due Diligence
Does your onboarding process include:
✓
Identifying the customer, beneficial owner and/or agent
✓
Assessing ML/TF/PF risk at the start of the relationship
✓
Identifying whether the client is a PEP
✓
Conducting sanctions screening
✓
No — further action required
7. Ongoing Customer Due Diligence
Does your process include:
✓
Monitoring transactions for suspicious activity
✓
Updating client information when necessary
✓
Adjusting risk profiles when trigger events occur
Examples of trigger events include:
- Changes in ownership or control
- Changes in business activities
- Changes in customer or transaction behaviour
8. AML Compliance Officer (AMLCO)
✓
AML Compliance Officer is an Australian resident
✓
AMLCO meets the fit and proper person requirements
9. Record-Keeping
Are records maintained to demonstrate:
✓
Customer due diligence
✓
Risk assessments
✓
Compliance with AML/CTF obligations
Records should be kept in English or easily convertible to English.
10. Core Records
Does your AML/CTF framework include records for:
✓
AML/CTF program
✓
Customer due diligence records
✓
Transaction records
✓
Staff training records
✓
Independent review records
✓
Suspicious activity reports
11. Reporting Obligations
Which reporting requirements apply to your business?
✓
Suspicious Matter Reports (SMR)
✓
Threshold Transaction Reports (TTR)
✓
Annual Compliance Reports
✓
Unsure — seek professional advice
Using This Checklist: Review each section carefully. Identify any gaps in your compliance framework. Implement policies or procedures to address those gaps. Keep records of actions taken for at least seven years.
Tip: This checklist is a starting point – seek professional advice to ensure your business meets all regulatory requirements.
A–Z
AML/CTF Program
Internal policies and procedures that explain how a reporting entity meets its AML/CTF obligations.
Annual Compliance Report
A yearly report submitted to AUSTRAC outlining how a reporting entity has complied with AML/CTF requirements.
Beneficial Owner
An individual who owns 25% or more, or otherwise controls, an entity such as a company or trust.
Designated Services
Services listed under Section 6 of the AML/CTF Act that carry potential money laundering or terrorism financing risk.
Reporting Entity
A business that provides designated services and must comply with AML/CTF legislation.
Senior Manager
A person involved in making decisions affecting a significant part of the business.
Suspicious Matter Report (SMR)
A report submitted to AUSTRAC when suspicious activity or potential criminal conduct is identified.
Threshold Transaction Report (TTR)
A report submitted to AUSTRAC for cash transactions of AUD $10,000 or more.
Disclaimer: This publication has been prepared with care but is provided for general information purposes only. It does not constitute legal, financial or professional advice.
Information contained in this publication may change and may not always reflect the most current regulatory developments. You should not act or rely on the information without obtaining professional advice specific to your circumstances. Please contact us if you would like to discuss how these matters may apply to you.
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