AML/CTF reforms: why AUSTRAC’s first enforcement wave may arrive sooner than expected
Over a month into Australia’s expanded anti-money laundering and counter-terrorism financing (AML/CTF) regime, up to 50,000 businesses that were required to enrol with AUSTRAC have not done so. These businesses (including law firms, accountants, real estate agents and property services firms) are readily identifiable through registers maintained by ASIC, state law societies, and accounting and other industry bodies.
With AUSTRAC confirming that enrolment of new entities is among its highest enforcement priorities for FY2026-27 under the amended Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), those yet to register face a real and immediate risk of fines and enforcement action.
For investment funds and financial services businesses, the reforms are also relevant where structures, transactions or service providers bring them into contact with newly regulated entities, or where AML/CTF uplift is needed across fund operations, customer due diligence, outsourcing and transaction monitoring.
How many new entities have enrolled?
As of 13 August 2026, there are 39,520 new reporting entities. While this more than triple the size of the prior regulated population, it falls well short of the Attorney-General’s estimate of 89,557. The breakdown of enrolled entities, compared with entities expected to be affected, is as follows.
| Industry | Expected enrolments | Actual enrolments | Shortfall (% enrolled) |
|---|---|---|---|
| Accounting services | 28,223 | 13,390 | -14,833 (47 per cent) |
| Legal services | 17,059 | 6,450 | -10,609 (38 per cent) |
| Trust and company services | 7,057 | — | — |
| Conveyancers | — | 1,580 | — |
| Real estate | 36,408 | 17,830 | -18,578 (49 per cent) |
| Dealers in precious metals and stones | 812 | 270 | -542 (33 per cent) |
| Total | 89,557 | 39,520 | -50,037 (44 per cent) |
So where is everyone?
To date, there is no clear explanation for the shortfall. However, some of the likely causes for the missing 50,000+ entities include businesses:
- being unaware of their obligations;
- actively deciding not to comply with the Act; or
- choosing to restructure their operations, or even close their businesses, rather than comply with the Act.
How will AUSTRAC respond?
Much attention has been given to the record-shattering fines imposed by AUSTRAC on banks and casinos for non-compliance with AML/CTF laws. Less attention has been given to AUSTRAC’s practice of issuing volumes of infringement notices to enforce procedural compliance obligations under section 184(1) of the Act, including to non-enrolled entities providing ‘designated services’.
AUSTRAC also has a ready-made mechanism for identifying who has not enrolled. Many new reporting entities, including lawyers, accountants, conveyancers, and real estate agents, are already required to register with state or industry bodies. AUSTRAC can request those membership lists, cross-reference them against its own enrolment register, and identify non-compliant entities quickly. Entities that have not enrolled should not assume they have gone unnoticed.
What newly regulated entities should do now
If you operate in one of the newly regulated sectors, you should urgently confirm whether you are one of the 50,000+ missing reporting entities. Businesses that should pay specific attention include lawyers, accountants, conveyancers, or any firm dealing with property, financial services, or other transactions on behalf of clients (such as property industry services, collection agents, and storage businesses). Failure to enrol is a contravention of section 51B(1) of the Act, and can result in an infringement notice.
If you have already enrolled, the focus now turns to implementation. Make sure your AML/CTF policies and procedures are documented, a compliance officer is in place, and your staff are trained on identifying and reporting suspicious matters. AUSTRAC’s early enforcement attention is likely to fall on suspicious matter reporting. This is the clearest signal of whether an entity is genuinely engaging with its obligations or simply going through the motions. Make sure your business understands the risk profile of its clients and services and is able to act on that understanding. Not every high-risk relationship needs to be exited, but a program left on the shelf will not survive AUSTRAC scrutiny.
Our specialist AML/CTF team can assist with tailored AML/CTF programs, risk assessments, and compliance frameworks. For general information about Australia's AML/CTF regime, please visit our AML/CTF online guide.
This article was prepared with the assistance of Marcus Jones, Law Graduate.
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