AUSTRAC has released detailed guidance on the upcoming AML/CTF reforms, which introduce a significantly expanded, more risk-focused and outcomes-based regime. These reforms affect both existing reporting entities and a wide cohort of newly regulated professions – including lawyers and accountants – who will need to comply with the AML/CTF Act for the first time.
Currently Regulated – What’s Changing and What It Means for You
A move from Designated Business Groups to Reporting Groups
One of the most significant structural changes is the shift from designated business groups (DBGs) to reporting groups.
Under the new model:
- Reporting groups will be easier to form and maintain, with fewer eligibility restrictions.
- Members of a reporting group will be able to share key AML/CTF functions, including program elements, risk assessments, customer identification procedures, and transaction monitoring methodologies.
For many AFSL-regulated businesses and wholesale fund managers that currently rely on DBGs to centralise compliance functions, this shift will require a review of existing group arrangements to ensure they align with the new rules so you are ready to amend enrolment details and comply from 31 March 2026.
Updated roles, responsibilities and accountability
The reforms introduce clearer and more prescriptive expectations around:
- AML/CTF governance
- Formal assignment of roles within your AML/CTF Program – including new ‘Fit and Proper’ requirements for the AML/CTF Compliance Officer
- Approvals by designated Senior Managers
- Board oversight roles
Additional designated services may now apply
Some service expansions may now fall within the definition of a designated service under revised categories.
For example, those wholesale funds undertaking property development or property sales activities will be providing additional designated services that need to be captured in enrolment details and the AML/CTF Program.
Financial advisers need to assess whether they are providing any of the new designated services relating to assisting with the establishment of companies or trusts (including SMSFs) as these are broadly defined.
A substantial overhaul of your AML/CTF Program
AUSTRAC has made it clear that AML/CTF Programs must move away from being “check-box” documents and toward practical, risk-based, outcomes-focused frameworks.
What this means:
- Your Program must be tailored to your business.
- The business-wide risk assessment becomes the central pillar of your compliance framework.
- The Program must demonstrate how controls manage the specific ML/TF risks identified in your assessment.
- AUSTRAC expects Programs to be “living and breathing” documents, reviewed and updated regularly – not prepared once and filed away.
Most existing reporting entities will need a near-complete rewrite of their AML/CTF Program to meet the new requirements.
Changes to CDD and ongoing customer monitoring
While CDD remains risk-based, the reforms introduce refinements including:
- Clearer triggers for enhanced CDD.
- Stronger obligations to understand customer purpose and expected transaction behaviour.
- More explicit requirements for ongoing monitoring and review over the customer lifecycle.
This means onboarding procedures and ongoing monitoring processes may require significant uplift – particularly for higher-risk clients.
Newly Regulated – What Lawyers and Accountants Need to Prepare For
Lawyers and accountants will be entering the AML/CTF regime for the first time, representing a major regulatory shift for these professions.
A completely new compliance regime and a new regulator
Legal and accounting practices will now be reporting entities under the AML/CTF Act, meaning:
- AUSTRAC will become a core regulator for your practice.
- You will need to understand and manage a new set of extensive statutory obligations.
- Compliance will require a new compliance regime, system changes, new processes, and extensive staff training.
Mandatory enrolment with AUSTRAC
Newly regulated entities can enrol with AUSTRAC from 31 March 2026 and must be ready to comply from 1 July 2026.
A documented, risk-based AML/CTF Program
This is the biggest change for legal and accounting firms.
Your Program must include:
- Business-specific ML/TF risk assessment
- Customer due diligence and verification processes
- Ongoing monitoring methodologies
- Employee screening, due diligence and training
- Governance, reporting and assurance mechanisms
Importantly, AUSTRAC has emphasised that Programs must be practical, operational and regularly updated – not generic templates.
New roles and responsibilities inside your practice
Firms will need to assign AML/CTF roles, including:
- AML/CTF Compliance Officer
- Senior Managers with responsibility to approve the AML/CTF Program, key customer relationships and reliance arrangements
- Operational owners for onboarding, monitoring, reporting and escalation
This may require new skills, new internal reporting lines, or new hires for some practices.
Customer due diligence, ongoing monitoring and reporting
Lawyers and accountants will now need to risk assess each client, verify client identities (including PEP and sanctions checks), understand the nature and purpose of client engagements, and conduct ongoing monitoring. Suspicious activity must be escalated and reported to AUSTRAC.
These obligations apply even where professional privilege exists, subject to carve-outs specified in AUSTRAC’s guidance.
Employee due diligence and training
All staff performing AML/CTF related activities must receive AML/CTF training and have undergone personnel due diligence (with periodic re-assessments).
How we can help
For $300 ex GST per month (regardless of users), all of the above will be taken care of via our Digital Compliance Platform which provides a holistic and ongoing AML/CTF Framework, enabling you to generate fully compliant but also fully customised risk assessments, policies and controls (fully customised not only to your industry but also how you will do things as a business), that can be updated instantly when things change.
Our dynamic task list will prompt you with all the things you need to be doing throughout the year to comply with your obligations, with audit trails to meet your record keeping obligations under the AML/CTF laws.
Our detailed training modules, guides, checklists and templates mean you’re not worried about whether what you’re doing is compliant – you have detailed prompts to ensure everything is captured and completed compliantly. Staff training is delivered within platform.
We are kicking off with a free 4 part webinar series on 25 November 2025. You can register here: Register for our Webinar
As long as you register, if you can’t make that time we can provide a recording to you afterwards). The webinar serious is intended to have you fully ready and equipped by 31 March 2026!
If you also want to join the wait list for our product, you can do so here: Wait list
We will be onboarding clients to the new AML/CTF Framework from February so get in early – first in best dressed.