Anti-money laundering & CTF
Australia's AML/CTF framework — designated services, AUSTRAC reporting, customer due diligence, and the 1 July 2026 Tranche 2 expansion to real estate, accountants, lawyers, conveyancers, TCSPs and precious metals dealers.
8
Obligations
1
Regulators
12
Recent enforcement
Regulators
Obligations (8)
- criticalCWLTHupcomingEnrol with AUSTRAC as a reporting entity
Tranche 2 entities must enrol with AUSTRAC by 29 July 2026.
- criticalCWLTHcurrentSuspicious matter, threshold, and IFTI reporting to AUSTRAC
Lodge SMRs, TTRs ($10K+ cash), and IFTI reports via AUSTRAC Online.
- criticalCWLTHcurrentCustomer due diligence (KYC) on every customer
Identify and verify every customer (and beneficial owner) before providing a designated service.
- criticalCWLTHupcomingMaintain a written AML/CTF program
Every reporting entity needs a documented AML/CTF program — Part A risk + Part B systems.
- criticalCWLTHcurrentDesignate an AML/CTF Compliance Officer
Reporting entities must designate a senior employee as AML/CTF Compliance Officer.
- criticalCWLTHcurrentDetect + enhance due diligence on Domestic + Foreign PEPs
AML/CTF Rules require detection + EDD on Politically Exposed Persons (foreign + domestic + international organisation).
- highCWLTHcurrentIndependent review of AML/CTF program
Reporting entities must arrange independent review of their Part A AML/CTF program at appropriate intervals.
- mediumCWLTHupcomingBeneficial ownership transparency (Tranche 3 — under consultation)
Proposed beneficial ownership register for unlisted companies and trusts — consultation through 2024-2025; commencement TBD.
Recent enforcement
- austraccivil penalty$19.0M2024AUSTRAC v SportsBet Pty Ltd
Sportsbet admitted that its Part A AML/CTF program did not appropriately assess and mitigate ML/TF risks across its business for almost 8 years.
- austraccivil penalty2024AUSTRAC v Entain (Ladbrokes / Neds parent)
AUSTRAC alleges Entain failed to maintain compliant AML/CTF program + Customer Due Diligence over a multi-year period.
- austraccivil penalty$4.0M2024AUSTRAC v Bell Financial Group
Bell Financial failed to conduct adequate enhanced customer due diligence on high-risk customers including those with PEP and adverse media flags.
- austracreview2024AUSTRAC compliance assessments — PEP detection 2024
AUSTRAC concluded compliance assessments of multiple reporting entities focusing on PEP detection + enhanced due diligence.
- austraccivil penalty$67.0M2024AUSTRAC v SkyCity Adelaide
SkyCity admitted serious + systemic AML/CTF non-compliance including failure to identify high-risk customers + insufficient program.
- austraccivil penalty$450.0M2023AUSTRAC v Crown Melbourne and Crown Perth
Crown admitted to serious and systemic non-compliance with AML/CTF obligations across both venues — inadequate Part A program, failure to risk-assess customers, failure to conduct enhanced customer due diligence on high-risk customers including 60 specific individuals.
- austraccivil penalty$1300.0M2020AUSTRAC v Westpac Banking Corporation
Westpac admitted contravening the AML/CTF Act on over 23 million occasions, including failing to report 19.5 million IFTI transactions to AUSTRAC over nearly 5 years and inadequate ongoing customer due diligence for high-risk transactions involving child exploitation typologies.
- austraccivil penalty$1300.0M2020AUSTRAC v Westpac (LitePay child exploitation)
AUSTRAC alleged Westpac contravened AML/CTF Act 23M times — including via LitePay payments to child exploitation hotspots in SE Asia.
- austraccivil penalty$700.0M2018AUSTRAC v Commonwealth Bank of Australia
CBA failed to report 53,506 IFTI threshold transactions to AUSTRAC on time, failed to assess risks for IDM machines, and failed to monitor known suspicious customers.
- austraccivil penalty$700.0M2018AUSTRAC v CBA (IDM machines)
AUSTRAC alleged CBA failed to file 53K+ TTRs + had systemic IDM machine AML failures.
- austraccivil penalty$45.0M2017AUSTRAC v Tabcorp
Tabcorp failed to maintain an adequate AML/CTF program, failed to identify customers, and failed to report 108 suspicious matters.
- austraccivil penalty$45.0M2017AUSTRAC v Tabcorp
AUSTRAC alleged Tabcorp had systemic AML/CTF compliance failures over 5+ years.