Australia’s AML/CTF reforms represent a fundamental shift from a prescriptive, compliance-based regime to a flexible, outcomes-focused framework – prioritising the effective prevention of money laundering, terrorism financing and proliferation financing, rather than merely following prescriptive rules.
Outcomes-based regime
This new approach requires reporting entities to demonstrate that their AML/CTF programs are both compliant and demonstrably effective in managing and mitigating ML/TF risks.
The regime also introduces a more dynamic, risk-based approach. Reporting entities must conduct thorough risk assessments and produce policies and procedures to mitigate and manage the ML/TF/PF risks they have identified and assessed, as well as policies, procedures, systems and controls to ensure they comply with the AML/CTF Act, Rules and regulations.
The AML/CTF reforms establish an outcome-based compliance framework that prioritises effectiveness and risk management, and moves beyond a prescriptive, check-box approach. Under the regime, reporting entities are required to demonstrate that their AML/CTF programs are effective in mitigating and managing their risks of money laundering, terrorism financing, and proliferation financing.
The reforms remove the current obligation for AML/CTF programs to be structured with a separate Part A and Part B. Now, an AML/CTF program must comprise two essential components:
- a comprehensive assessment of the entity’s exposure to ML/TF/PF risks, and the development of policies that are tailored to address those risks.
- The measures to respond to the risks faced must be embedded within the organisation’s internal policies, systems, and controls, reinforcing a culture of compliance within the business.
The revised AML/CTF Act provides reporting entities the flexibility to structure their AML/CTF program in a manner that aligns with the nature, size, and complexity of their business, and effectively identifies, mitigates and manages their ML/TF/PF risks.
We are here to help
While 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.
If you would like to discuss any of the above with one of our AML/CTF specialists, please reach out.
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