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Australia’s 2026 AML/CTF reforms will expand obligations to new sectors and require existing entities to uplift their programs, making compliance a strategic priority rather than a procedural task.
A strong compliance culture relies on leadership, clear governance, staff training, tailored risk assessments, and ongoing monitoring – moving from a checkbox exercise to a core part of business integrity.
Now is the time for leaders to drive cultural change and invest in the systems and behaviours needed to meet the 2026 requirements.
As Australia prepares for the landmark Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) reforms – set to take effect in the coming months – businesses across sectors face a pivotal moment not just to comply with how to manage financial crime risk, but to transform themselves for the better.
Contents
The real challenge lies in building a culture that embeds AML obligations into the DNA of an organisation.
From regulation to culture: why compliance should be more than a program
The 2026 reforms introduce sweeping changes. From 1 July 2026, AML/CTF obligations will extend to new sectors including lawyers, accountants, real estate professionals, property developers, and dealers in precious stones, while existing reporting entities must comply with updated rules by 31 March 2026. These changes are not just procedural; they demand a shift in mindset from reactive compliance to proactive risk management.
A compliance culture goes beyond policies and embeds ethical behaviour, accountability, and risk awareness into every layer of an organisation. This means cultivating a culture where AML/CTF responsibilities are understood, owned, and acted upon at every level of the business.
Key elements of a strong compliance culture
These essential steps are not just operational, they are cultural and require organisations to embed AML thinking into their values, behaviours, and decision-making frameworks:
Governance and leadership: The governing body must set the tone from the top, establishing clear accountability through governance structures and appointing compliance officers who champion AML/CTF values.
Staff training and awareness: Regular AML/CTF training across all levels ensuring all employees from frontline staff to senior executives understand their roles in identifying and mitigating financial crime risks.
Service mapping and risk assessment: Identifying designated services and assessing their exposure to money laundering and terrorism financing risks. Risk assessments and program policies must be tailored to the organisation’s services, delivery channels and client base.
Customer Due Diligence (CDD): Implementing robust CDD processes that go beyond identity verification to assess behavioural, transactional and geographic risk.
Ongoing monitoring and reporting: A compliance culture is dynamic as it evolves with changing threats, regulatory expectations, and internal learnings to create systems that support continuous oversight, timely reporting, and adaptive responses to emerging threats.
A call to action for new entrants
For newly regulated entities, the reforms represent both a challenge and an opportunity. Many are engaging with AML/CTF for the first time, and the learning curve is steep. Technical readiness alone is not enough. Firms must foster a culture where compliance is seen as a shared responsibility and not just the domain of risk teams. This includes aligning AML efforts with broader organisational values, incentivising ethical behaviour, and creating feedback loops that encourage continuous improvement.
The role of leadership in cultural change
Leadership plays a pivotal role in shaping compliance culture and organisations that treat AML/CTF as a strategic priority, and not just a regulatory burden, will be better positioned to navigate the reforms and build trust with regulators, clients, and the public.
Culture as a competitive advantage
In a post-AML reform landscape, compliance culture will be a differentiator for a business’s long-term success. As AUSTRAC shifts toward risk-based supervision, organisations that embrace compliance culture will be better positioned to navigate scrutiny and lead with integrity. Organisations that embrace AML/CTF obligations as part of their ethical and operational identity will not only meet regulatory expectations, but they will also strengthen their resilience, reputation, and long-term value.
How you know you’re ready
AML/CTF reforms readiness is demonstrated through effective governance and evidence of progress. The board should have clear oversight on uplift activities underway, ask the right questions, and challenge management on progress while maintaining visibility of compliance risks. To have confidence that your organisation is genuinely reform‑ready, the board should expect to see evidence of the following:
Targeted gap assessments against the new AML/CTF regime can help organisations understand their compliance gaps, determine what must change and identify the scale of change required. Clear visibility of what needs to change is a strong marker of readiness.
A structured uplift plan with timelines, accountabilities and milestones shows that the business is moving from intention to execution. A realistic timeline, aligned to regulatory guidance as it is released, is critical. Readiness also depends on ensuring current AML/CTF controls continue to operate effectively while change is underway.
Your ML/TF risk assessment should be up to date, and aligned to your services, delivery channels and geographic exposure, showing that you understand your current risks and have controls designed to mitigate those risks.
Independent reviews confirm if your AML/CTF Program, CDD, monitoring and governance controls are designed and operating effectively, and are not just documented in your Policy. This can provide the board with confidence that AML/CTF controls are operating effectively while change is underway.
We’re here to help
Reach out to our team of experts to learn more about the AML/CTF reforms and how we can help build a compliance culture across your organisation.
Learn more about how our Anti-Money Laundering reforms services can help you
How leadership teams can implement effective ML/TF risk management, ongoing AML/CTF compliance, and the successful definition and embedding of an organisation's AML/CTF compliance culture.
Grant Thornton is a leading specialist in AML/CTF risk management and can assist businesses by providing tailored AML/CTF risk management and compliance services
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