How do proposed changes to the AML/CTF Act affect my current program?

The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024represents the most significant reform to Australia's AML/CTF framework since the original Act was passed in 2006. The changes affect both existing Tranche 1 reporting entities and the new Tranche 2 entities now brought into the regime.

Key changes in the 2024 amendments

• Expanded reporting entity base: Accountants, lawyers, real estate agents, trust and company service providers, and dealers in precious metals and stones are now reporting entities — the largest expansion of the AML/CTF regime since its inception
• Modernised CDD framework: The amendments update the customer due diligence requirements, aligning them more closely with FATF Recommendation 10 and introducing a clearer risk-based structure for simplified, standard, and enhanced CDD
• Streamlined program structure: The Part A / Part B program distinction is retained, but the rules have been updated to provide clearer guidance on what each part must contain
• Beneficial ownership: Stronger requirements to identify and verify the beneficial owners of legal entities, reflecting FATF's Recommendations 24 and 25
• Correspondent banking and third-party reliance: Updated rules for when you can rely on the due diligence conducted by another regulated entity

What existing reporting entities need to do

If you are an existing Tranche 1 reporting entity — for example, a remittance dealer or a casino — your existing AML/CTF program needs to be reviewed against the new requirements and updated to reflect:

• The updated CDD procedures and documentation standards
• The new beneficial ownership requirements
• Any changes to your risk assessment methodology required by the updated risk-based approach guidance

Transition timeline

• 29 November 2024: Royal Assent of the Amendment Act
• 31 March 2026: New Tranche 2 reporting entities must be enrolled with AUSTRAC
• 31 July 2026: AML/CTF programs must be in place for all new Tranche 2 entities

AUSTRAC guidance and rules

The 2024 amendments are accompanied by updated AML/CTF Rules (the subsidiary legislation that contains the detailed technical requirements). AUSTRAC also publishes guidance documents that explain how it interprets and will apply the new rules. Review AUSTRAC's official guidance at austrac.gov.au as a supplement to legal advice.