Overview of Updates to Australian AML/CTF module - 1 May 2026
Below is a comprehensive summary of the updates made to the AML/CTF module as part of the 31 March 2026 legislative amendments, including the introduction of Tranche 2 requirements and associated transitional arrangements. Please note a more detailed summary of changes will be provided in the form of the Monthly Summaries issued sent in the week commencing 4 May 2026. Enclosed with this update is the summary of the changes made to the obligations in the AU AML-CTF module (AMLCTF Apr 2026 Uplift - Basic Summary).
1. A modernised AML/CTF framework
The module has been significantly updated to align with the new AML/CTF regime coming into effect from 2026. This includes:
- Bringing forward obligations that will apply under the updated framework
- Incorporating Tranche 2 entities and requirements into the core obligation set
- Updating content to reflect current regulatory expectations and AUSTRAC guidance
In practical terms, this ensures your compliance register reflects where the law is going, not just where it has been.
2. Transitional rules – what still applies today
A key feature of this update is the inclusion of Transitional Rules, which clarify how obligations apply between now and full implementation.
This means:
- Some existing obligations (e.g. initial Customer Due Diligence and IFTI reporting) are retained in their current form during the transition period
- Certain new requirements are not mandatory until later dates (e.g. 2029), even though they are now visible in the framework
- You can clearly distinguish between:
- What you must comply with today
- What you need to prepare for in the future
3. Expanded scope (including Tranche 2)
The update introduces and integrates obligations relevant to newly regulated sectors (Tranche 2), including:
- Designated services expansion
- Reporting group structures and compliance arrangements
- Enhanced customer due diligence and risk management expectations
- Virtual assets, remittance, and value transfer obligations
This ensures organisations entering scope can operationalise compliance from day one, while existing entities can understand how obligations are evolving.
4. New and enhanced content areas
Several areas have been strengthened or introduced, including:
- Reporting groups and group compliance structures (new content driven by customer demand)
- Enhanced AML/CTF program requirements, including governance and risk assessments
- Updated reporting obligations (TTRs, value transfers, cross-border movements)
- Expanded coverage of virtual assets and international value transfers
- Clarified obligations for record keeping, audits, and regulatory engagement
5. Structural simplification and archiving
As part of the uplift, a large number of legacy obligations have been:
- Archived where they are no longer relevant or have been consolidated
- Replaced with streamlined, future-aligned obligations
- Deduplicated to remove overlap and improve usability
This results in a cleaner, more intuitive compliance framework, making it easier to navigate and apply.
6. What you should do next
We recommend that customers:
- Review impacted areas of their compliance program (particularly CDD, reporting, and AML/CTF programs)
- Identify which obligations apply:
- Now (mandatory)
- Later (transitional / future state)
- Begin planning for Tranche 2 readiness if applicable
- Engage with your LexisNexis contact for any further details
Overview of Updates to Australian AML/CTF module - 17 April 2026
With the volume of regulatory activity relating to the Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) regime in Australia, we are reaching out to provide an update on the current status of your Regulatory Compliance AML/CTF module and associated updates.
Current state
In preparation for the reformed AML/CTF regime, we began work well ahead of commencement.
From late 2025, we introduced the incoming AML/CTF framework within the module as future‑facing obligations, reflecting how the legislation and rules were expected to operate from 31 March 2026.
At that point, the reforms largely replaced the existing framework, and our content was structured accordingly to support early awareness and planning.
As a result, new obligations were introduced with the title preceded by [2026 Amendment - 31 March 2026]. These include:
- [2026 Amendment - 31 March 2026] Designated Services
- [2026 Amendment - 31 March 2026] Identifying designated services
- [2026 Amendment - 31 March 2026] Exempt designated services
- [2026 Amendment - 31 March 2026] Enrolments with AUSTRAC
- [2026 Amendment - 31 March 2026] New enrolments
- [2026 Amendment - 31 March 2026] Advise AUSTRAC of changes to enrolment details
- [2026 Amendment - 31 March 2026] Removal from Reporting Entities Roll
- [2026 Amendment - 31 March 2026] AML/CTF Programs
- [2026 Amendment - 31 March 2026] Conducting an ML/TF risk assessment
- [2026 Amendment - 31 March 2026] AML/CTF policies
- [2026 Amendment - 31 March 2026] AML/CTF program responsibilities of governing bodies and compliance officers
- [2026 Amendment - 31 March 2026] Correspondent Banking Relationships
- [2026 Amendment - 31 March 2026] Due diligence assessment of correspondent banking relationships
- [2026 Amendment - 31 March 2026] Prohibition on shell bank relationships
- [2026 Amendment - 31 March 2026] Customer Due Diligence
- [2026 Amendment - 31 March 2026] Use and disclosure of personal information for the purposes of verifying an individual’s identity
- [2026 Amendment - 31 March 2026] Initial customer due diligence
- [2026 Amendment - 31 March 2026] Specific customer due diligence requirements for different customer types
- [2026 Amendment - 31 March 2026] Specific customer due diligence requirements for different customer types
- [2026 Amendment - 31 March 2026] Ongoing customer due diligence: monitoring
- [2026 Amendment - 31 March 2026] Simplified and enhanced customer due diligence
- [2026 Amendment - 31 March 2026] AML/CTF countermeasures
- [2026 Amendment - 31 March 2026] Threshold Transaction Reports (TTRs)
- [2026 Amendment - 31 March 2026] Identifying threshold transactions
- [2026 Amendment - 31 March 2026] Preparing and submitting a threshold transaction report
- [2026 Amendment - 31 March 2026] Suspicious Matter Reports (SMRs)
- [2026 Amendment - 31 March 2026] Identifying suspicious matters
- [2026 Amendment - 31 March 2026] Preparing and submitting a suspicious matter report
- [2026 Amendment - 31 March 2026] Reporting for Global Value Transfers and Virtual Assets
- [2026 Amendment - 31 March 2026] Reports of international value transfer services
- [2026 Amendment - 31 March 2026] Reports of transfers of value involving unverified self-hosted virtual asset wallets
- [2026 Amendment - 31 March 2026] Transfers of Value
- [2026 Amendment - 31 March 2026] Determining institutional roles in value transfers
- [2026 Amendment - 31 March 2026] Information management in value transfers
- [2026 Amendment - 31 March 2026] Cross-border Movement (CBM) Reports
- [2026 Amendment - 31 March 2026] Reporting cross-border movements of physical currency
- [2026 Amendment - 31 March 2026] Reporting cross-border movements of bearer negotiable instruments
- [2026 Amendment - 31 March 2026] Compliance Reporting, External Audits and Information Requests
- [2026 Amendment - 31 March 2026] AML/CTF compliance reports
- [2026 Amendment - 31 March 2026] Information requests
- [2026 Amendment - 31 March 2026] Keep open notices
- [2026 Amendment - 31 March 2026] External audits
- [2026 Amendment - 31 March 2026] Record Keeping for AML/CTF
- [2026 Amendment - 31 March 2026] Retention of records of customer due diligence
- [2026 Amendment - 31 March 2026] Retention of records pertaining to AML/CTF program obligations
- [2026 Amendment - 31 March 2026] Retention of records of transactions
- [2026 Amendment - 31 March 2026] Dealing with Proceeds or Instruments of Crime and Preventing the Support of Terrorism
- [2026 Amendment - 31 March 2026] Prohibition against dealing with proceeds or instruments of crime and supporting terrorism
- [2026 Amendment - 31 March 2026] Complying with orders in relation to the proceeds of crime
- [2026 Amendment - 31 March 2026] AUSTRAC Industry Contribution Levy
- [2026 Amendment - 31 March 2026] Scope of the AUSTRAC industry contribution levy
- [2026 Amendment - 31 March 2026] Calculation and payment of the AUSTRAC industry contribution levy
- [2026 Amendment - 31 March 2026] Sanctions
- [2026 Amendment - 31 March 2026] Complying with autonomous sanctions
- [2026 Amendment - 31 March 2026] Complying with United Nations Security Council sanctions
- [2026 Amendment - 31 March 2026] Regulation of the Remittance Sector
- [2026 Amendment - 31 March 2026] Registration requirements
- [2026 Amendment - 31 March 2026] Registration management and compliance obligations
- [2026 Amendment - 31 March 2026] Regulation of the Virtual Asset Sector
- [2026 Amendment - 31 March 2026] Registration requirements
- [2026 Amendment - 31 March 2026] Registration management and compliance obligations
In January and February 2026, AUSTRAC and the Department of Home Affairs publicly confirmed that AML/CTF Transitional Rules were being developed to manage the shift from the legacy framework to the reformed regime. These announcements clarified that the reforms would not operate as a single cut‑over, but instead through a dual‑framework transitional period, with certain legacy obligations continuing alongside new requirements until approximately 31 March 2029.
Changes were not made to the obligations identified above during this time, with reassessment planned to take place once there was clarity on the final structure of the dual systems in operation.
Upcoming Content Enhancements (reflecting the Transitional Rules)
The AML/CTF Transitional Rules 2026 were formally made by the Minister for Home Affairs on 27 March 2026. Following their release, we commenced a structured update of our AML/CTF module to reflect how the regime now operates in practice during the transition period.
As a result, content that had previously been positioned as purely future‑state (identified above) has required further review to ensure that it accurately reflects both the existing and reformed frameworks operating in parallel. Areas being prioritised for update include those most directly impacted by the Transitional Rules, such as:
- Retention of applicable customer identification procedures (ACIP) until 2029
- Transitional period in respect of Initial customer due diligence (initial CDD)
- Transitional period during shift from international funds transfer instruction (IFTI) to international value transfer service (IVTS) regime
- Transitional period in respect of virtual asset service providers (VASPs)
- Shift from designated business groups (DBGs) to reporting groups
These updates are focused on:
- Clearly distinguishing what applies now, what applies later, and what is future‑state only
- Preserving legacy obligations where the Transitional Rules explicitly allow them to continue
- Incorporating additional clarification and guidance introduced by the transitional framework
We are currently finalising these changes and are working to publish updates by the week imminently.
These updates are intended to improve clarity and ensure the AML/CTF module accurately reflects the way obligations apply during the transition period through to 2029.
Future planning – Tranche 2 and beyond
Looking ahead, we will continue to enhance the AML/CTF module to support:
- Tranche 2 entities AM/CTF obligations commencing from 1 July 2026
- Progressive alignment with the new AML/CTF framework as legacy obligations are phased out
- Continued transition from legacy concepts to the reformed regime over time, rather than through a single cut‑over event
As future‑state obligations approach commencement (including those currently deferred under the Transitional Rules), we will continue to:
- Update content in line with regulatory guidance
- Clearly signal upcoming changes in advance
- Maintain a clear separation between current, transitional, and future obligations
This staged approach is designed to support practical implementation, reduce uncertainty, and ensure content remains accurate and usable throughout the transition period.
Overview of Updates to Australian AML/CTF module - 16 January 2026
On 29 August 2025, the Anti-Money Laundering and Counter-Terrorism Financing Rules 2025 were tabled before Federal Parliament, as alerted by us on 4 September 2025 (see alert AMLCTF497, inter alia).
We are in the process of incorporating the new Rules into the affected obligations registers, which we anticipate will be completed in the near term.
In the meantime, in order to give customers some clarity as the effect of the new Rules, when compared with the draft Rules contained in the Exposure Draft, please find below a summary of the key differences between the two.
1. Customer Due Diligence (CDD)
-
ED2:
- Allowed delayed verification of beneficial owners and trust beneficiaries for up to 30 days under broader conditions.
- Simplified due diligence for low-risk customers (e.g., government bodies, listed companies).
- Limited requirement to identify “person on whose behalf the customer acts” only in fiduciary/trust contexts.
-
Final Rules:
- Delayed verification narrowed: now only permitted in specific scenarios (e.g., onboarding where immediate verification is impractical).
- Low-risk customer relief retained but conditions tightened (must document risk rationale).
- Additional prescriptive requirements for ongoing monitoring and trigger events (e.g., material change in customer profile).
2. AML/CTF Program Structure
-
ED2:
- Proposed flexible AML/CTF program design with risk-based measures and allowance for group-level programs replacing “designated business groups.”
-
Final Rules:
- Group compliance clarified: now requires documented governance arrangements and mandatory intra-group information sharing protocols.
- Additional board-level oversight obligations for large reporting entities.
3. Reporting Obligations
-
ED2:
- Introduced granular data fields for Suspicious Matter Reports (SMRs) and Threshold Transaction Reports (TTRs), including counterparties, payment channels, and transaction types.
- Required alignment with AUSTRAC’s new digital reporting standards.
-
Final Rules:
- SMR/TTR data requirements retained, but implementation deferred for some fields until 2029 to allow system upgrades.
- Added explicit requirement for international funds transfer instructions (IFTIs) to include payer and payee details in line with FATF travel rule.
4. Enrolment & Registration
-
ED2:
- Enhanced scrutiny for Remittance Service Providers (RSPs) and Virtual Asset Service Providers (VASPs): AML/CTF capability checks, criminal history, international operations.
-
Final Rules:
- Same framework retained, but added mandatory annual attestation of AML/CTF capability for high-risk sectors.
- Introduced sector-specific exemptions for low-risk professional services under Class Exemption Rules.
5. Value Transfer & Travel Rule
-
ED2:
- Required payer/payee information for remittances and transfers of value.
-
Final Rules:
- Maintained requirement but clarified gift card issuers and stored-value facilities obligations (still contentious; AUSTRAC guidance pending).
6. Transitional & Timing
- ED2: Proposed staged implementation starting 31 March 2026 for existing entities and 1 July 2026 for Tranche 2 sectors.
- Final Rules: Same dates confirmed, but threshold transaction reporting and SMR changes deferred until 2029
7. Structural Changes
-
Final Rules introduced additional clarifications not in ED2:
- New definitions (e.g., “unique identifier,” “domestic politically exposed person”).
- Explicit interaction with Privacy Act and legal professional privilege.
Where to find full provision-level mapping?
AUSTRAC published a renumbering and amendment ready reckoner showing section-by-section changes between ED2 and the final Rules. You can download it from AUSTRAC’s AML/CTF reform page.
The Anti-Money Laundering and Counter-Terrorism Financing Rules 2025 are found here: Anti-Money Laundering and Counter-Terrorism Financing Rules 2025 - Federal Register of Legislation
Enclosed is a document mapping the changes made in the June 2025 update to the Australian AML/CTF module. The document includes the following sections:
- Topics in the current and future state of the module - because of the way information is currently structured in the module, and with certain topics getting differing emphasis under the new framework, customers may find topic-based grouping useful for categorising their controls and responses. in some instances, certain topics are no longer mentioned under the new legislation, in which case they will be marked with N/A
- which individual obligations currently, and will in future, align with that topic. if a topic is no longer mentioned, then no directly mapped future obligations will be mentioned. However, if there is equivalent content available under a different topic, then this will be identified
- explanation notes for the transition and customer impacts to support understanding of the information
Transition Period:
Several existing obligations have been republished and updated to reflect the current state of the AML/CTF regime, which remains in effect until the amendments due in March 2026. This ensures that requirements remain current and accurate for the near term.
Separation of Future-Looking Requirements:
Content that addresses requirements coming into effect in March 2026 has been separated from the current obligations. These future-focused requirements have been moved into new obligations, each assigned a unique ID, to make it easier for reporting entities to identify and focus on what is already in force versus what is planned.
Creation of New Obligations:
A wide range of new and updated obligations have been created following the upcoming changes effective in March 2026. These cover a wide range of topics, including but not limited to:
- Customer identification and due diligence
- Designated and exempt services
- Reporting (such as Threshold Transaction Reports and Suspicious Matter Reports)
- Record-keeping across different compliance areas
- Cross-border transfer procedures, including physical currency and BNIs
- Additional operational topics such as external audits, keep open notices, and AUSTRAC’s industry contribution levy
Targeted Clarifications and Consolidations:
- Clarity & Usability: Several obligations have been rewritten or consolidated for improved clarity, usability, and alignment with both state and federal frameworks.
- Expanded Guidance: Additional details have been provided on topics such as correspondent banking arrangements, digital financial services, and the roles within value transfer chains.
- Enforcement & Reporting Enhancements: There is enhanced guidance on the operational and compliance impacts of key requirements, particularly in relation to new AML/CTF measures and the associated regulatory oversight.
Legacy Obligations:
Some obligations have been archived (for example, following the repeal of the Financial Transactions Reports Act 1988) as part of an overall update. This move brings legacy compliance subjects under the modernized AML/CTF regime.
How This Impacts Reporting Entities
-
Immediate Compliance:
Entities should continue to follow the current obligations that reflect the AML/CTF regime until March 2026. The changes ensure that all current practices are aligned with up-to-date regulatory language. -
Preparation for Future Amendments:
With future-oriented content now in separate obligations, reporting entities can prepare in advance for the changes coming in March 2026 without mixing them with current requirements. -
Clear Guidance on New Areas:
The new framework reflects a stronger emphasis on risk-based decision making and reinforces AUSTRAC’s expectation of more proactive, holistic and intelligence-driven compliance. The introduction of many new obligations provides detailed guidance on emerging areas of AML/CTF compliance, including additional emphasis on risk-based assessment, expanded due diligence practices, and revised reporting thresholds and procedures. -
Enhanced Transparency:
Structural changes, such as the segregation of designated service roles and detailed record-keeping instructions, aim to increase transparency across the compliance process and help entities clearly understand their responsibilities.
In Summary
- Current vs. Future: These future-facing obligations are expected to evolve over time in line with AUSTRAC’s ongoing guidance and regulatory updates. Existing obligations have been updated to remain valid until March 2026, with future changes moved to separate, clearly identified obligations.
- Improved Clarity: Content across various obligations has been clarified, consolidated, or rewritten, ensuring that entities can easily understand their present obligations versus upcoming changes.
- Comprehensive Coverage: The updates and new obligations span a broad range of compliance areas, ensuring thorough coverage of all key operational, reporting, and risk management aspects associated with the AML/CTF regime.
This structured approach is intended to facilitate smoother regulatory compliance and better prepare entities for the imminent amendments to Australia’s AML/CTF regime.