AML/CTF changes are here – cutting through the noise for Aged Care & Retirement Village leaders

Insight

By: Kate Wilkie, Neil Jeans

Quick summary
  • From 1 July, AML/CTF changes apply, but not all organisations will be captured – it depends on your operating model.
  • Misinterpretation is the key risk; compliance where it’s not needed increases cost but under-compliance exposes you to regulatory risk.
  • A targeted assessment provides clarity on obligations and where to focus effort.
From 1 July, the updated AML/CTF regime* takes effect for entities which provide real estate or property based services. This is wider than the Real Estate sector and subsequently, there is already commentary, interpretation and confusion in the aged care market.
Contents

The reality is not every residential aged care operator will be captured by the new requirements – but some will, and whether you are or not comes down to the details of how your business operates.

*Updated AML/CTF regime

Where you need to focus:

If your organisation directly sells or transfers real estate (including long-term leaseholds >30 years) without an independent agent, you may likely fall within scope.

Where you may not:

  • Traditional loan/licence models used in residential aged care
  • Transactions brokered by an independent real estate agent

Why this matters:

This is not just a compliance exercise – it’s about making the right strategic decisions for your business. Getting this wrong can lead to unnecessary cost, effort and operational disruption.

Equally, underestimating your obligations can expose your organisation to regulatory risk.

A considered assessment enables you to: 

  • Avoid unnecessary compliance uplift where the legislation does not apply
  • Make informed and defensible decisions aligned to your operating model
  • Move forward with clarity and confidence, backed by a clear rationale
  • Prioritise effort and investment where it genuinely matters

Understand your obligations in a complimentary 30-minute session

At Grant Thornton, we cut through the complexity to provide clear, practical advice tailored to your operating model. You’ll walk away with a confident view of where you stand and what you need to do next.

Book a complimentary, no-obligation 30-minute discussion to help you quickly assess your position and identify any immediate priorities.

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Disclaimer
This is general information only. You’ll need to assess the legislation in detail against your full operating model to determine whether you’re captured under the Act.

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Visit our Anti-Money Laundering reforms page
Learn more about how our Anti-Money Laundering reforms services can help you