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New AML/CTF regime lands on 1 July: are governance professionals ready?

Australia’s AML/CTF reforms expand obligations beyond finance, extending to many governance professionals. Catherine Maxwell, the Governance Institute’s General Manager of Policy & Advocacy, explains what is changing, who is impacted and how to prepare effectively.

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Australia’s AML/CTF regime is undergoing its most significant expansion in nearly two decades. From 1 July 2026, anti-money laundering and counter-terrorism financing obligations will apply to a broad range of professional service providers, including many governance professionals. The Governance Institute has a guide to help members understand what is changing, whether they are captured, what steps to take to comply with the new requirements and where to access authoritative resources.

Australia is a founding member of the Financial Action Task Force (FATF), the international authority on standards to combat financial crime. FATF recommends that AML/CTF obligations extend to professional service providers, recognising that sectors such as legal, accounting, and company services can be exploited to launder the proceeds of crime. Until these reforms, Australia was one of only a small number of FATF member countries that had not yet extended obligations to these sectors. A poor FATF mutual evaluation result would risk Australia being grey-listed, with significant consequences for its international financial relationships.

The reforms apply to Tranche 2 entities, which are businesses providing certain newly regulated designated services. They include:

  • Real estate professionals (agents, buyers’ agents, property developers)
  • Professional service providers – lawyers, conveyancers, accountants, and trust and company service providers (TCSPs)
  • Dealers in precious metals, stones and products

Importantly, not every business in these industries is automatically ‘captured’. Capture depends on whether the specific services provided are designated services listed in section 6 of the AML/CTF Act.

Our FAQ take you through a series of steps to help you understand whether you might be affected by the amendments. The key question is not your job title, but the nature of the services you provide. If you provide any of the following for or on behalf of clients, you are likely to be providing designated services:

  • Acting as company secretary of a client’s company
  • Providing a registered office, business address, or correspondence address for a company, partnership, or other legal arrangement
  • Acting as or arranging for another person to act as a director of a company, partner of a partnership, or similar position in other legal arrangements
  • Assisting in the sale, purchase, or transfer of a company or other body corporate or legal arrangement
  • Assisting in organising, planning, or executing a transaction for equity or debt financing relating to a body corporate (or proposed body corporate) or legal arrangement (or proposed legal arrangement)
  • Assisting in the establishment, administration, or management of a trust, company, or similar legal arrangement
  • Holding funds or assets on behalf of a client in connection with any of the above

See our AML/CTF Frequently ask questions

The obligations for Tranche 2 entities providing professional and trust/company services commence on 1 July 2026. The following table sets out the key milestone dates:

Date

Milestone

10 Dec 2024 AML/CTF Amendment Act 2024 receives Royal Assent
31 Mar 2026 AUSTRAC enrolment opens for Tranche 2 entities. Tranche 1 (existing) entity obligations updated.
1 Jul 2026 AML/CTF obligations formally commence for Tranche 2 entities (including TCSPs and professional services)
29 Jul 2026 Deadline to complete AUSTRAC enrolment (28 days after obligations commence)
Ongoing 2026 AUSTRAC continues to develop and release sector-specific guidance in partnership with industry

The FAQ also provides links to resources to assist you in understanding your potential obligations under the reforms.

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