Is your business unknowingly enabling money laundering?

In today’s interconnected economy, businesses of all sizes and sectors could, without realising it, be caught up in money laundering schemes. With Tranche 2 Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) laws coming into effect on 1 July 2026, it is more important than ever to understand what money laundering is, how it creates hidden risks, and what your organisation can do right now to protect itself.

What is money laundering?

Money laundering is the process by which funds acquired through criminal or illegal activities are made to appear legitimate.

It generally involves three stages:

• Placement – introducing illicit funds into the financial system.
• Layering – hiding the money through complex or multiple transactions.
• Integration – reintroducing the laundered funds back into the economy as “clean” money.

This process fuels ongoing criminal enterprises, undermines trust in the financial system, and damages the reputation of legitimate businesses.

The hidden ways money laundering can occur in your business

Money launderers often exploit legitimate business services and financial channels, sometimes without the business even knowing. Below are some of the less obvious ways laundering can occur.

Digital-facilitated laundering and weak oversight
Crypto exchanges: AUSTRAC recently ordered an external audit of Binance Australia, citing “serious concerns” over inadequate oversight, limited staffing, and weak customer identification protocols.

Structured cash deposits and retail fronts
Launderers break large sums into smaller transactions to avoid detection. In one anonymised AUSTRAC case, a retail business owner deposited over $2.5 million AUD in structured cash transactions to evade reporting requirements.

Cyber-enabled identity fraud
Criminals use stolen identities, fake SIM cards, and fraudulent email accounts. AUSTRAC identified a case where more than 60 bank accounts were opened across Australian banks using false identities.

Organised cash networks via businesses
Suspicious deposit patterns—especially just under the $10,000 AUD reporting threshold—can indicate laundering. AUSTRAC uncovered a syndicate that used third-party company accounts and frequent deposits to move illicit funds.

High-profile sector failures
High-risk industries such as casinos, gambling, real estate, and hospitality attract heightened regulator scrutiny. Example: Entain (owner of Ladbrokes) faced court action for accepting over $152 million AUD from high-risk, criminal-profile customers.

What your business can do today

To reduce the risk of unknowingly enabling money laundering, businesses should:

Start or refresh a risk-based AML/CTF program
Adopt a risk-based approach as a foundation.
Monitor structured deposits, unusual third-party payments, and customers pushing transactions just below thresholds.

Improve customer due diligence (CDD)
Enforce robust identity checks, even for smaller transactions.
Apply heightened scrutiny for clients showing red flags such as anonymised activity or offshore associations.

Actively monitor transaction patterns
Watch for repeated transactions just under reporting thresholds.
Track multi-account routing or sudden high-value transfers.

Conduct independent reviews
Have your AML/CTF program independently reviewed to ensure relevance and prevent compliance drift.

Train your team
Provide AML/CTF compliance training so staff can recognise red flags.
Use refresher or booster courses to reduce fatigue and knowledge gaps.

Elevate governance and accountability
Senior leaders must take ownership of AML/CTF compliance.
Weak oversight increases the risk of errors and regulator intervention.

Preparing for Tranche 2 AML/CTF reforms

The upcoming Tranche 2 AML/CTF reforms will expand obligations to industries such as lawyers, accountants, real estate, and more. Many businesses that have never faced AML/CTF requirements before will now come under regulatory scrutiny.
Failing to prepare could expose your organisation to severe penalties, reputational damage, and regulator action. Learn more in our blog ‘What happens if your business fails to comply with AML laws’

Safetrac can help

At Safetrac, we specialise in delivering legally-authored AML/CTF compliance training that helps organisations stay compliant and reduce risk.
If you’d like help tailoring AML/CTF training for your business, get in contact with Safetrac today and let our experts support you every step of the way.