What Legal, Compliance and Procurement Teams Need to Know

Significant reforms to Australia’s Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act) are on the horizon. These changes, designed to strengthen Australia’s response to financial crime, introduce important considerations for corporate legal, compliance and procurement leaders.

• 31 March 2026: New requirements commence for businesses already regulated under the AML/CTF Act.
  
  
• 1 July 2026: Legal, accounting, real estate and jewellery businesses begin their compliance journey under the Act.
  
  

These timelines align with Australia’s upcoming mutual evaluation by the Financial Action Taskforce (FATF) in 2026. The pace reflects both urgency and global expectations for robust anti-financial crime systems.

A Shift Towards Risk-Based Thinking

At the core of these reforms is a sharper regulatory focus on managing real financial crime risks. AUSTRAC is evolving its approach to prioritise outcomes that reduce the harm caused by money laundering, terrorism financing and other serious offences.

For legal and compliance professionals, this means moving beyond programs that merely look compliant on paper. Instead, AUSTRAC expects businesses to demonstrate that they are actively identifying, assessing and mitigating money laundering and terrorism financing risks in practical and meaningful ways.

Expectations for Currently Regulated Businesses

If your organisation is already under the AML/CTF Act, AUSTRAC expects you to:

• Maintain and strengthen existing controls.
• Develop and document clear implementation plans for transitioning systems and processes to the new framework.
• Show sustained effort and progress, with short-term tactical improvements where necessary.
• Continue managing ML/TF/PF risks effectively during this transition.

Organisations with robust systems should embed reform-related changes seamlessly. However, those with gaps or lapses in compliance may attract closer regulatory scrutiny.

Expectations for Newly Regulated Businesses

For organisations in legal, accounting, real estate and jewellery sectors, AUSTRAC expects that by 1 July 2026, you will:

• Enrol as a reporting entity (from 31 March 2026).
• Implement an AML/CTF program, either through AUSTRAC’s starter program (available December 2025) or a tailored solution.
• Appoint an AML/CTF Compliance Officer.
• Train staff on AML/CTF requirements and practical processes.
• Be ready to identify clients, ask questions, and report suspicious activity.

AUSTRAC recognises these obligations are new for many businesses and acknowledges that capability will build over time. However, visible and honest efforts to meet obligations will be critical from day one.

AUSTRAC’s Approach to Support and Enforcement

As the commencement dates draw closer, AUSTRAC will provide:

• Guidance materials and starter programs to help businesses prepare.
• Industry education and forums to support capability building.
• Regulatory priorities and timelines (to be published July 2025) detailing what businesses should do each month leading up to commencement.

Enforcement in newly regulated sectors will focus on entities that wilfully ignore their obligations or are suspected of facilitating financial crime.

Act Now to Build Resilience

AUSTRAC is clear: businesses aren’t expected to achieve perfection on day one, but sustained effort and risk awareness are essential. For corporate legal, compliance and procurement teams, now is the time to:

• Assess current frameworks and identify gaps.
• Plan for system and process upgrades.
• Engage stakeholders across the organisation to build awareness and capability.
• Avoid last-minute implementations that can expose the business to risk.

How Roilti Can Help

Roilti works with organisations to establish compliant transactional workflows, streamline processes and build operational resilience into AML/CTF programs. With the 2026 reforms approaching, we can help your teams  navigate these changes with confidence.

Stay ahead of AML/CTF reforms. Contact Roilti to explore how we can support your transactional compliance systems and strengthen your financial crime risk management framework.

#AUSTRAC #AMLReforms #AustraliaCompliance #CorporateCompliance #GovernanceRiskCompliance #ComplianceLeadership #FutureOfCompliance #RiskMitigation #SmarterCompliance