Insight

Moving from Designated Business Group to the Reporting Group model

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Quick summary
  • Creating a reporting group under the amended Australian AML/CTF Act 2024 is appropriate when related entities seek to streamline their compliance efforts, share resources, and manage common AML/CTF risks more efficiently. This concept is particularly beneficial for entities with complex structures or those operating in multiple jurisdictions, as it allows for a coordinated approach to risk management and compliance. 
  • By adopting the reporting group model, entities can achieve cost savings, enhanced compliance, and optimised resource utilisation. However, they must also address challenges such as effective coordination, resource allocation, and maintaining robust internal controls. 
  • The lead entity within a Reporting Group is responsible for overseeing the implementation of the AML/CTF obligations, developing and maintaining ML/TF/PF Policies and Risk Assessments, and must ensure that all members comply with the AML/CTF Act and Rules.   
The AML Reforms introduce the concept of a 'reporting group'—a flexible model that allows both related and unrelated entities to manage and mitigate ML/TF risks under a single, comprehensive AML/CTF Program.

Moving from a Designated Business Group (“DBG”) to a Reporting Group under the new AML/CTF regime offers opportunities for efficiency and consistency but may bring significant governance, liability, and change management risk and challenges. Careful planning, early action, and robust oversight by the lead entity are essential for a successful transition. 

  • The AML/CTF reforms replace the DBG model with the new ‘reporting group’ concept, which allows a broader range of related entities - including non-AML/CTF reporting entities,  to be included in a single group for compliance purposes. 
  • Reporting groups can now be formed not only by corporate groups but also by unrelated entities (e.g., franchises, joint ventures, professional networks) if they share similar ML/TF risks and wish to coordinate compliance. 
  • A lead entity must be nominated to oversee the Reporting Group’s AML/CTF compliance. This entity is legally responsible for the compliance of all group members, including developing and maintaining the group-wide AML/CTF program, coordinating risk assessments, and ensuring all obligations are met. 
  • The lead entity must be able to control and enforce compliance across the group, maintain access to all records, and document which member is responsible for which obligations.  
  • Delegation of tasks is possible, but ultimate liability remains with the lead entity. 
  • Assess your structure: Review whether your organisation operates as a corporate group, business group, or franchise, and whether members share similar ML/TF risks and customer profiles. 
  • Evaluate compliance efficiency: Consider if a single group-wide program will reduce duplication, streamline reporting, and lower costs through shared resources and consistent controls. 
  • Governance and liability: Carefully weigh the ability of the lead entity to oversee and enforce compliance, especially in large or disparate groups, and be prepared for the lead entity to assume the risk of civil penalty for non-compliance by any member. 
  • Eligibility: Confirm your group meets any conditions in the AML/CTF Rules for forming a reporting group, as not all structures will qualify. 
  • Change management: The transition requires significant technical and business change, including updating risk assessments, policies, technology, and embedding new practices through strong project and stakeholder management. 
  • Start early: Begin analysis of the obligations, challenges and risks well before the March 2026 deadline. 
  • Focus on outcomes: Compliance is not just about documentation - it must be embedded in daily operations and culture, with a focus on harm reduction and effective risk management. 
  • Engage stakeholders: Successful adoption depends on strong leadership, clear communication, and buy-in across all levels of the organisation and Reporting Group members. 

We are here to help 

Whilst the new AML/CTF requirements won't be a requirement until 31 March 2026 for existing reporting entities and 1 July 2026 for new reporting entities, it is vital to start planning and preparing for compliance now. 

With a short lead time to compliance and limited AML/CTF experts across Australia, demand will only continue to increase as the compliance date approaches.   

Contact one of our AML/CTF experts if you would like to discuss any of the above. 

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