Understanding changes to AML/CTF obligations and the Privacy Act for reporting entities
InsightUnderstanding changes to AML/CTF obligations and the Privacy Act: what reporting entities need to know.
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By: Neil Jeans, Katherine Shamai, Martin Stone, Annelies Homersham
11 Mar 2025 10 min read

The new AML/CTF Act introduces significant amendments to extend coverage to a broader range of virtual assets and virtual asset service providers (VASPs) through a revised set of designated services, and revised terminology.
The amended AML/CTF Act replaces the term “digital currency” with “virtual asset”, and “exchange” with “service provider”, and designates the following services provided by VASPs under Table 1 of section 6 of the AML/CTF Act:
These changes will force a wider array of businesses to comply with AML/CTF obligations, including cryptocurrency exchanges, wallet providers, decentralised finance (DeFi) platforms, and ICO facilitators.
The exchange between virtual assets and fiat currency involves converting digital currencies (e.g. Bitcoin, Ethereum) into fiat currencies (e.g. USD, EUR, AUD) and vice versa. This process allows users to buy digital currencies using fiat money or sell their digital currencies to receive fiat money.
Several types of businesses provide exchange services between virtual assets and fiat currencies:
These businesses bridge the gap between traditional finance and the emerging world of digital assets, making it easier for individuals and businesses to participate in the digital economy.
The exchange between one or more forms of virtual assets involves converting one type of digital currency or token into another. For example, exchanging Bitcoin (BTC) for Ethereum (ETH) or converting a stablecoin like Tether (USDT) into a different cryptocurrency like Litecoin (LTC). This type of exchange allows users to diversify their digital asset holdings or take advantage of different blockchain features and benefits.
Several types of businesses facilitate the exchange between different forms of virtual assets:
These businesses play a role in the digital asset ecosystem, enabling users to manage and diversify their cryptocurrency portfolios efficiently.
The transfer of virtual assets involves moving digital currencies or tokens from one wallet or account to another. This service is essential for enabling transactions between users, whether for personal transfers, payments for goods and services, or other financial activities. The transfer process ensures the ownership of the virtual asset is securely and accurately updated on the blockchain.
Several types of businesses facilitate the transfer of virtual assets:
These businesses also play a role in the digital asset ecosystem, ensuring that virtual assets can be transferred efficiently and securely across different platforms and users.
Safekeeping and administration of virtual assets involve securely storing and managing digital currencies or tokens on behalf of clients. This service ensures that virtual assets are protected from theft, loss, or unauthorised access. It also includes managing the private keys that control access to these assets, ensuring they are kept safe and accessible only to an authorised individual.
Several types of businesses offer safekeeping and administration services for virtual assets:
These businesses play a crucial role in the digital asset ecosystem by ensuring that virtual assets are stored securely and managed efficiently.
This service involves assisting with the creation, marketing, and sale of new virtual assets, such as tokens or cryptocurrencies, typically through mechanisms like initial coin offerings (ICOs) or security token offerings (STOs). These services can include underwriting, advisory, and other financial services that support the issuer in bringing their virtual asset to market.
Several types of businesses are involved in providing financial services related to the offer and sale of virtual assets:
These businesses play a crucial role in the successful launch and distribution of new virtual assets, ensuring that issuers can navigate the complex regulatory landscape and reach potential investors effectively.
The amended AML/CTF Act in Australia has broadened the definition of virtual assets to include various types of digital representations of value. The following are the main classes of virtual assets and their features:
Although the new AML/CTF requirements won't be enforced until April-2026 for existing entities and July 2026 for new entities, it is vital to start planning and preparing for compliance with the revised AML/CTF requirements 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.
Understanding changes to AML/CTF obligations and the Privacy Act: what reporting entities need to know.
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