2024 in Review: A landmark year for Australia’s Anti-Money Laundering/Counter-Terrorism Financing Reform

Australia’s Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) laws are about to undergo their most significant update since their inception. The long-awaited Tranche 2 reforms are finally moving forward, and in December 2024, the government introduced these changes through the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024.

These reforms, commencing from 31 March 2026, are set to expand the scope of the AML/CTF regime. For the first time, professions like lawyers, accountants, real estate agents, and other high-risk service providers will be subject to the same compliance obligations as traditional financial institutions.

At a glance

Summary of changes

The Tranche 2 reforms are a key part of Australia’s efforts to stay ahead of financial crime and terrorism financing, ensuring a safer and more secure financial landscape. These reforms introduce a more adaptable, risk-based approach to regulation, designed for a fast-evolving digital economy.

Here’s a breakdown of what the reforms will include:

• Expanded coverage:
  A broader range of services and professions will fall under the AML/CTF regime, including DNFBPs and digital currency exchanges. The reforms close regulatory gaps in sectors previously seen as vulnerable to financial crime.
• Risk-based approach:
  Rather than applying uniform rules across the board, the government is adopting a flexible framework. Businesses will be expected to assess their own risks and apply proportionate compliance measures.
• Regulation of virtual assets and services:
  Tranche 2 brings services related to virtual assets under AUSTRAC’s oversight, in line with international standards for cryptocurrency regulation.
• Stronger oversight of high-risk sectors:
  Industries such as real estate and high-value goods trading are being targeted due to their known vulnerabilities to money laundering.
• AUSTRAC’s expanded role:
  AUSTRAC will regulate compliance for newly captured sectors, ensuring businesses implement risk-based programs, monitor transactions, and report suspicious activity.

Who needs to act

The upcoming reforms will affect a wide range of high-risk services, including:

• Legal professionals: Law firms and individual practitioners involved in financial transactions
• Accountants: Firms and solo practitioners offering financial services
• Real estate agents and developers: Entities handling property transactions
• Dealers in precious metals and stones: Businesses dealing in high-value goods
• Digital currency providers: Exchanges and service providers handling virtual assets

It’s estimated that between 70,000–90,000 businesses will be affected.

Why is this important?

While the compliance deadline is 1 July 2026, early preparation is critical. Taking action now can help businesses avoid rushed efforts later and ensure smooth adoption of the new regulations. Developing a robust AML/CTF framework early will reduce risk and support long-term compliance.

Steps to take now

To ensure compliance with the upcoming AML/CTF law changes, businesses should act in the following areas:

• Update your AML/CTF program

Action: Review and revise your AML/CTF policies and procedures to meet the new regulatory requirements.
Why: The expanded law demands more comprehensive and industry-specific compliance strategies

• Conduct a risk assessment

Action: Regularly assess your exposure to money laundering and terrorism financing risks.
Why: Tailoring your compliance measures starts with understanding your vulnerabilities.

• Train your staff

Action: Provide targeted training to staff, particularly those in compliance roles.
Why: Well-trained staff are essential to ensuring your business meets legal obligations and avoids penalties.

• Prepare for the deadline

Action: Review your current compliance efforts and start making adjustments now.
Why: With new rules taking effect in July 2026, early action reduces last-minute pressure.

• Monitor changes from regulators

Action: Stay updated on further guidance and developments from AUSTRAC.
Why: Regulatory expectations may evolve ahead of the full rollout.

Learn more with:

• Anti-Money Laundering Legislation: Is your business complaint?
• Money Laundering and Human Rights: What’s the connection and why should we care?

By addressing these areas early, businesses can build strong compliance systems and avoid disruption.