Is your business ready for Australia’s new AML/CTF reforms?

Australia’s anti-money laundering and counter-terrorism financing (AML/CTF) regime is undergoing major reforms to bring it in-line with international standards set by global financial crime watchdog, the Financial Action Task Force.

New and reframed obligations will commence from 31 March 2026 for existing Reporting Entities (REs), and from 1 July 2026 numerous businesses operating in industries that were not previously covered by the regime will be regulated as ‘Tranche 2’ REs, including:

• Real estate agents and property developers (with inhouse sales teams);
• Lawyers and legal practices;
• Other professional service providers (e.g. trust and company service providers, corporate advisors, capital/debt arrangers);
• Virtual asset-related services providers (VASPs) (other than Digital Currency Exchanges which are already REs); and
• Dealers in precious metals/stones and products.

Existing and new Tranche 2 REs have significant work to do over the coming months to get ready to comply with the new AML/CTF obligations. Early business engagement and preparation is key.

Preparing for the reforms

New Tranche 2 REs will need to take proactive steps to understand their new AML/CTF obligations and prepare, which will require proactive assessments of ML/TF risks arising from the designated services they provide, as well as designing and implementing appropriate policies, procedures and controls within the business to mitigate these ML/TF risks.

Existing REs will need to consider what changes they will need to make to their existing AML/CTF programs, including their ML/TF risk assessment, to comply with the reforms, and whether they should have their AML/CTF program independently reviewed prior to or after making these changes.

How Gadens can assist

While the primary legislative reforms have passed into law, key details under the new regime are still being consulted on through AUSTRAC Rules instruments. These are expected to be finalised by AUSTRAC in August/September 2025 and published together with comprehensive AUSTRAC guidance materials.

Gadens’ Financial Services Regulatory team has extensive AML/CTF expertise and will publish further updates to assist both existing and new Tranche 2 REs prepare for these reforms. For more information about what these changes mean for your business, contact our team.

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Authored by:
Caroline Ord, Partner
Patrick Simon, Associate
Phillip Danh, Graduate