AML/CTF Act 2006 — reporting entity obligations (AU, incl. Tranche 2)
AML/CTF Act 2006 — reporting entity obligations (AU, incl. Tranche 2)
Governs anti-money laundering and counter-terrorism financing obligations for Australian reporting entities. Tranche 2 expanded coverage from 1 July 2026 to real estate, legal, accounting, conveyancing, trust/company services, and dealers in precious metals/stones. Applies to enrolment, AML programs, customer due diligence, transaction monitoring, reporting, and record keeping.
Source
- AML/CTF Act 2006 (C2006A00113) — legislation.gov.au
- AUSTRAC — "Your obligations" (report types, record keeping)
- AUSTRAC media release 30 Sep 2026 — infringement notices to non-enrolled businesses
- AUSTRAC infringement notices — Belside Pty Ltd, Kimberley Jane Black t/a Infoproperties (Oct 2026)
Criteria
| id | criterion | reference | applies-to | validation |
|---|---|---|---|---|
| AML-001 | A reporting entity shall enrol with AUSTRAC within 28 days of commencing a designated service. | AML/CTF Act s51B(1); AUSTRAC media release 30 Sep 2026 | all tranche-2 sectors | Enrolment confirmation record on file before first designated service |
| AML-002 | A reporting entity shall maintain an AML/CTF program (Part A risk assessment, Part B policies/procedures/controls) approved by senior management and reviewed at least annually. | AML/CTF Act; AUSTRAC program guidance | all reporting entities | Program document version-controlled; annual review record |
| AML-003 | A reporting entity shall appoint an AML/CTF compliance officer responsible for the program. | AML/CTF Act; AUSTRAC guidance | all reporting entities | Officer appointment record |
| AML-004 | A reporting entity shall conduct initial customer due diligence before providing a designated service — identity verification and beneficial ownership for entities. | AML/CTF Act CDD provisions; AUSTRAC guidance | all reporting entities | CDD records per customer (who/what/when/how verified) |
| AML-005 | A reporting entity shall conduct ongoing CDD — monitor transactions against the customer's risk profile and review risk ratings periodically. | AML/CTF Act ongoing CDD provisions; AUSTRAC guidance | all reporting entities | Ongoing review records; transaction monitoring logs |
| AML-006 | A reporting entity shall submit a suspicious matter report (SMR) within 3 business days of forming a suspicion on reasonable grounds (24 hours where terrorism-financing related); proof of offence is not required. | AUSTRAC "How to get your reporting right" (30 Sep 2026) | all reporting entities | SMR submission log with suspicion date and submission timestamp |
| AML-007 | A reporting entity shall submit a threshold transaction report (TTR) within 10 business days for transfers of $10,000 or more in physical currency (including foreign currency equivalent); electronic transfers, cheques and card payments do not trigger TTR. | AML/CTF Act ss5, 43; AUSTRAC TTR guidance | cash-handling sectors | TTR detection rules on physical-currency transactions ≥$10,000 |
| AML-008 | A reporting entity shall submit an international funds transfer instruction report (IFTI) for instructions to transfer funds into or out of Australia. [VERIFY: deadline — 10 business days per AUSTRAC] | AML/CTF Act; AUSTRAC obligations | fund-transfer services | IFTI detection rules on cross-border transfer instructions |
| AML-009 | A reporting entity shall keep records for 7 years: AML/CTF program records, CDD records, and transaction records related to designated services. | AUSTRAC "Your obligations" (record keeping) | all reporting entities | Retention policy + storage audit trail |
| AML-010 | A reporting entity shall submit an annual compliance report covering the previous calendar year. | AUSTRAC "Your obligations" (compliance reports) | all reporting entities | Annual report submission record |
| AML-011 | A reporting entity shall screen customers against sanctions and PEP lists (DFAT sanctions, politically exposed persons) and adverse media. | AUSTRAC guidance; DFAT sanctions lists | all reporting entities | Screening log per customer with list versions |
Penalty context
- AUSTRAC began issuing infringement notices 30 Sep 2026 to non-enrolled tranche-2 businesses (real estate, accounting, jewellery sectors): $21,840 per corporate entity, $4,368 per individual, accruing daily (s51B(1); s186A penalty calculation).
- Named actions: Belside Pty Ltd (Oct 2026), Kimberley Jane Black t/a Infoproperties (Oct 2026).
- AUSTRAC reports ~90% of businesses targeted with formal information requests have since enrolled — enforcement is live and escalating.
- Government Regulation Impact Statement: average ongoing compliance cost ~$23,250/year per entity (includes staff time).
Review cadence
- On any AUSTRAC guidance update, infringement action, or legislative amendment — minimum annual review; quarterly during tranche-2 bed-in.