Do I need to Comply?

If you operate a financial services business in Australia and the services you provide fall within the definition of designated services in Section 6 of the Anti-Money Laundering and Counter Terrorism Financing (“AML/CTF“) Act you are a Reporting Entity and will need to comply with the Act and the AML/CTF Rules.

If you:

 

some or all of the obligations in the AML/CTF Act and Rules will apply to you.

Who do the AML/CTF Obligations apply to?

Life Insurance services
Custodial/depository services
Superannuation fund management
Securities markets and investment services
Providing pension/annuity services or retirement savings accounts
Lease/hire purchase services
Loans or finance
Preparing payroll for other businesses
Issuing money/postal orders
Issuing stored value cards
Issuing travellers cheques

Services provided by Authorised Deposit-Taking Institutions ("ADIs")

Account and deposit-taking services
Chequebook access facilities
Debit card access facilities
Accepting electronic funds transfers

Currency (digital & fiat) services

Services provided which also require registration with AUSTRAC:

Digital Currency Exchange
Remittance services (money transfers)
Currency exchange services

You can find further information about your obligations here:

Professional services

From July 2026, services provided by accountants, lawyers, real estate professionals (Tranche 2 entities) were also required to comply. 

Buying or selling of real estate 
Management of bank, savings or securities accounts 
Organisation of contributions for the creation, operation or management of companies
Creation, operation, or management of legal persons or legal arrangements (e.g. trusts)
Receiving, holding, controlling or managing a person's money, accounts, securities, virtual assets or other assets as part of assisting the person in the planning or execution of a transaction
Assisting a person in the planning or execution of a transaction to buy, sell or transfer a body corporate legal agreement, including acting on their behalf in a transaction
Buying and selling of business entities

Metal and stone dealers

A business provides a designated service under Tranche 2 if it buys or sells precious metals, precious stones and/or precious products, where:

  1. the purchase involves the use of cash and/or virtual assets; and
  2. the total value (whether in a single transaction or via instalments) is A$10,000 or more (or foreign equivalent).

 

 

If a business that deals with precious metals, stones and products decides not to accept cash or virtual asset payments for any transaction above the $10,000 threshold, the business does not provide a designated service.

You can find further information for Tranche 2 entities here, including the timeline to comply and key obligations to be met.

What is the geographical link?

To have a geographical link to Australia, one of the following must apply to you:

  • Providing designated services at or through a permanent establishment in Australia
  • You are a resident of Australia providing designated services at or through a permanent establishment in a foreign country
  • You are a subsidiary of a company that is resident in Australia and providing designated services at or through a permanent establishment in a foreign country

Key obligations

All reporting entities must have an AML/CTF Program and meet certain ongoing obligations, including reporting to AUSTRAC. You can find out more about the obligations and which apply to you and the links below:

If you would like further information or assistance, please contact Sophie Grace directly.

AML/CTF Reforms

Sophie Grace can provide you with an AML/CTF Program and can assist you to tailor it to your business’ needs. We have three different options available to suit your business and finance needs.

Template Documents

You can purchase template documents from our online shop. The template is an instant download and includes prompts to help you tailor the document yourself. We have template documents for:

  • Tranche 1 Reporting Entities;
  • Item 54 Providers; and
  • Tranche 2 Entities.
Compliance Portal

Sign up to the Compliance Portal and receive the template AML/CTF Program Package, and obtain access to updated documents in light of any updates we make as new guidance or amended legislation is released. Choose between:

  • document-only plans;
  • consultation-only plans;
  • video and regulatory update plans; or
  • a combination of all three.
Tailored Documents

Sophie Grace can assist you to prepare the AML/CTF Program package based on your business’ specific requirements. Contact us to discuss further. 

Find everything you need in relation to the AML/CTF Reforms

Sophie Grace Compliance Portal

Sign up today for up-to-date compliance policies and regular consultation with our staff. Watch our demonstration video now!

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