Summary of changes for current reporting entities (Reform)

Read a summary of the changes impacting current reporting entities under the anti-money laundering and counter-terrorism financing (AML/CTF) reforms. 

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There are changes under the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 (the Amendment Act) to the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (the Act) and the new AML/CTF Rules. 

We’ve developed education resources to help you understand and meet your changed obligations. 

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To learn more about the reforms, go to:

Harm prevention approach to tipping off offence

Changes to the tipping off offence came into effect on 31 March 2025. The changes focus on whether disclosing information protected by the tipping off offence would or could reasonably be expected to prejudice an investigation. 

Learn more about tipping off. 

Enrolment and registration

Current reporting entities will need to update enrolment and registration details with information required under the new Rules where they provide one of the new designated services.

Learn more about: 

New AML/CTF program requirements

A major update to the AML/CTF program requirements shifts the focus from a compliance-based approach to a risk-based, outcomes-oriented approach. These changes will help you adopt more effective measures tailored to the actual risks your business reasonably faces.

You no longer need to separate your program into Part A and Part B. You can organise your AML/CTF program in a way that meets your needs, provided it meets the requirements of the Act.  

What the new requirements include

The new requirements include:

  • Risk assessment: you must identify and assess risks related to money laundering and terrorism financing, as well as your proliferation financing risks. We refer to these as ML/TF risks.
  • AML/CTF policies: you must establish appropriate AML/CTF policies to manage and mitigate the ML/TF risks you identify and comply with your AML/CTF obligations. If your proliferation financing risk is low and is appropriately addressed by policies related to money laundering and terrorism financing, you don’t have to implement specific counter-proliferation financing policies.
  • Roles and responsibilities: the new framework emphasises the role of governing bodies and senior management in overseeing ML/TF risk and AML/CTF compliance. It also emphasises their role in taking reasonable steps to comply with AML/CTF obligations. It’s now an explicit requirement to appoint a fit and proper AML/CTF compliance officer responsible for implementing the AML/CTF program. 

These changes come into effect on 31 March 2026. 

Learn more about your AML/CTF program obligations. 

Reporting groups replace designated business groups

Existing designated business groups will cease to exist on 31 March 2026. 

If you are in a designated business group, or want to save costs through group-wide compliance, you will need to take steps to create a reporting group. 

Learn more about reporting groups. 

Customer due diligence requirements

The changes to customer due diligence (CDD) requirements ensure a risk-based approach that is more targeted and flexible approach. This focuses on outcomes that help mitigate risks associated with higher-risk customers and transactions. 

CDD is separated into initial CDD and ongoing CDD.

Initial CDD

Based on the information reasonably available to you and before providing any designated services, you must both:

  • establish certain matters on reasonable grounds
  • identify the ML/TF risk of the customer.

This generally means determining where the customer fits in your ML/TF risk assessment. This is based on factors like the: 

  • kind of designated service they’re receiving
  • kind of customer they are
  • way you’re providing the service to the customer
  • countries relevant to the provision of the service. 

It includes identifying all of the following: 

  • your customer
  • their representatives
  • any person that your customer is receiving a service on behalf of
  • any beneficial owner of the customer. 

These persons must also be screened to establish if they’re any of the following: 

There are circumstances when you can delay initial CDD where essential to avoid interrupting the ordinary course of business or not carry out particular steps in the initial CDD process. 

Ongoing CDD

You must monitor and manage ML/TF risks relating to the customer by applying ongoing CDD measures that are appropriate to each customer. 

The new laws also include:

  • Simplified CDD: you may apply simplified CDD in specific circumstances, such as where the ML/TF risk of the customer is low and no enhanced CDD triggers apply. This reduces the compliance burden for low-risk customers.
  • Enhanced CDD: you must apply enhanced CDD when the ML/TF risk of the customer is high and in specified circumstances. For example, when your customer is a foreign PEP, or a suspicious matter reporting obligation arises in relation to their conduct.
  • Pre-commencement customers: you must monitor pre-commencement customers for significant changes that could increase their ML/TF risk to medium or high or trigger a suspicious matter reporting obligation. If such changes occur, you must complete both initial and ongoing CDD on the customer.

CDD exemptions

CDD exemptions are also being streamlined, including:

  • Keep open notices: these notices replace the current ‘chapter 75 law enforcement operation exemptions’. Law enforcement can now issue notices directly to reporting entities. This allows reporting entities to defer certain CDD actions if they reasonably believe undertaking certain CDD obligations could alert a customer to a law enforcement investigation.
  • Lower CDD threshold for gambling sector: the Act reduces the CDD exemption threshold for gambling services from $10,000 to $5,000 to align with international standards set by the Financial Action Task Force. 

These changes come into effect on 31 March 2026. 

Learn more about CDD.

New reportable details for SMRs and TTRs

The new Rules expand the reportable details required in suspicious matter reports (SMRs) and threshold transaction reports (TTRs). 

From 1 July 2026 to 30 March 2029 current reporting entities will have the choice to submit an SMR and TTRs using the current form, or a new form that requires you to provide new information. 

This will only apply if you were on the Reporting Entity Roll on 30 March 2026. New regulated entities cannot apply to enrol before 31 March 2026. 

Learn more about the changes to SMRs and TTRs.

The travel rule

The new laws will apply to businesses that provide domestic and international value transfer services, for example financial institutions, remittance providers, virtual asset service providers and some gambling service and currency exchange providers. It will require businesses that transfer money, virtual assets or property on behalf of customers to collect, verify and pass on key information about the transfer.

The travel rule will ensure transparency across the transfer chain, helping businesses manage ML/TF risks while making essential information available to regulators and law enforcement. 

These changes come into effect on 31 March 2026. 

Learn more about the travel rule.

International value transfer service reporting

International value transfer service (IVTS) reporting will replace the current international funds transfer instruction (IFTI) reports. The reporting obligation will now lie with the reporting entity closest to the Australian customer. 

This will improve the framework for tracking international transfers of value – which includes the transfer of money, virtual assets or other property – by enabling more accurate customer information to be included in reports. Currency exchange and gambling services will also move from IFTI reporting to IVTS reporting. 

There’s a new reporting obligation for reporting transfer activity to or from unverified self-hosted virtual asset wallets.

IVTS reporting will start after 2026 in a transitional arrangement from IFTI reporting. 

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You can find out more about these changes in schedule 8 to the Amendment Act. 

Revised definition of bearer negotiable instruments

The definition of bearer negotiable instruments (BNIs) has been revised in response to industry feedback that the previous definition was overly broad and created reporting burdens. 

The new definition aligns with Financial Action Task Force (FATF) recommendations and excludes non-bearer instruments. This will reduce unnecessary reporting.

These changes come into effect on 1 July 2026. 

Learn more about bearer negotiable instrument reporting. 

The new laws will provide clearer protections for information or documents that are subject to legal professional privilege (LPP). 

Nothing in the amended Act affects the right of a person to refuse to give information (including by answering a question) or produce a document if the information or document would be privileged from being given or produced on the ground of LPP. 

These changes come into effect on 1 July 2026. 

Learn more about legal professional privilege. 

Foreign branches and subsidiaries

The new laws will simplify and clarify requirements for reporting entities with foreign branches and subsidiaries. The changes allow foreign branches and subsidiaries to use systems and controls that suit foreign conditions, if they achieve the required outcomes. 

The obligations under the Act must be complied with overseas, unless a foreign law prohibits it.

Certain obligations will only apply to designated services that are provided at a permanent establishment in Australia. 

These changes come into effect on 1 July 2026. 

Learn more about foreign branches and subsidiaries.

Repeal of Financial Transaction Reports Act 1988

The Financial Transaction Reports Act 1988 (FTR Act) was repealed on 7 January 2025. 

Affected businesses include: 

  • solicitors
  • businesses that buy and sell traveller’s cheques
  • motor vehicle dealers who act as insurance providers or intermediaries
  • online remitters which don’t provide designated services at or through a permanent establishment in Australia.

These businesses are no longer required to make reports under the FTR Act for transactions occurring from 7 January 2025 but may still have ongoing confidentiality and record keeping obligations. 

Learn more about your ongoing obligations following the FTR Act repeal.

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This guidance sets out how we interpret the Act, along with associated Rules and regulations. Australian courts are ultimately responsible for interpreting these laws and determining if any provisions of these laws are contravened. 

The examples and scenarios in this guidance are meant to help explain our interpretation of these laws. They’re not exhaustive or meant to cover every possible scenario.

This guidance provides general information and isn't a substitute for legal advice. This guidance avoids legal language wherever possible and it might include generalisations about the application of the law. Some provisions of the law referred to have exceptions or important qualifications. In most cases your particular circumstances must be taken into account when determining how the law applies to you.

Last updated: 16 Oct 2025
Page ID: 1159

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