Anti-Money Laundering

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Money laundering enables criminals to conceal the origins of illicit funds, often through complex structures, transactions, legitimate businesses, or cross-border activity. 

The impacts of money laundering are far-reaching, fuelling organised crime, distorting markets, and undermining the integrity of financial systems. 

When left unchecked, it can:

  • Increase the influence of criminal networks and corruption
  • Undermine legitimate businesses and fair competition
  • Weaken financial institutions and destabilise economies
  • Reduce government revenue and increase compliance costs
  • Damage national and corporate reputations, deterring investment.

For businesses, understanding anti-money laundering obligations and implementing effective controls is critical. 

BDO’s forensic specialists work with organisations across all sectors, adopting a risk-based approach to assess risk exposure, design practical compliance frameworks, conduct independent reviews and respond to regulatory scrutiny with confidence.

Anti-money laundering and counter-terrorism financing act (AML/CTF act)

Under Australia’s current anti-money laundering and counter-terrorism financing (AML/CTF) regime, businesses providing financial, gambling, bullion, remittance and digital currency exchange services, are regulated by AUSTRAC to ensure they comply with their obligations in having sufficient systems and controls in place that manage their risks of money laundering and terrorism financing.

The AML/CTF reform takes effect on 1 July 2026, aligning Australia with international standards. These reforms will expand the scope of regulated services, known as Tranche 2, to include real estate professionals, dealers in precious metals and stones, conveyancers, lawyers, accountants, and trust and company service providers.

It is crucial for all businesses providing designated services, whether current or newly reporting under Tranche 2, to understand their obligations, develop or update their AML/CTF framework, and ensure they are meeting compliance by starting preparation now.

AML reform timeline

31 Mar 2025
Icon Changes to the tipping off offense commence.
May - Jun 2025
Icon Second Consultation on AML/CTF Rules.
Jul 2025
Icon Member/industry-specific consultation on core guidance.
Aug - Sept 2025
Icon Rules Published.
New entities captured by the legislation should consider their business services and structure, risk appetite and potential areas of impact.
Oct 2025
Icon Publication of core guidance.
Dec 2025
Icon Publication of Tranche 2 sector-specific guidance.
Entities should refine their thinking specific to the organisation and plan for implementation, while assessing available information and tools to ease the compliance process.
31 Mar 2026
Icon Changes to obligations for Tranche 1 and virtual assets service providers. Tranche 2 enrolment commences.
Entities need to enrol, execute and embed implementation strategies.
1 Jul 2026
Icon AML/CTF obligations commence for Tranche 2 entities.
Entities should consider testing and review for compliance, remediating any identified issues.
Post-2026
Icon International value transfer services (IVTS) reporting will commence under transitional arrangements.

Please note: These timeframes may be subject to change by AUSTRAC.

Our anti-money laundering services


Independent reviews

We provide independent and objective reviews of your AML/CTF framework against AUSTRAC standards and regulatory requirements, giving you confidence that your framework is compliant, current and effective. 

We test the design and operation of your controls, and assess your compliance culture to provide clear, actionable recommendations based on best practice across industry.

Risk identification and assessment

We look at all aspects of your organisation to identify and assess the extent of any risks that may be present, taking into account new technologies, identity fraud and overseas trends. 

We help you identify gaps for criminal exploitation by taking a risk-based approach, helping you ensure your resources are focused where it matters.

AML/CTF uplift

Businesses currently regulated under Tranche 1 may have identified gaps in their AML/CTF frameworks or experienced regulatory scrutiny. 

We can support you with targeted remediation strategies to strengthen compliance and ensure your controls are both effective and fit for purpose.

KYC advisory

The team at BDO are experienced Know Your Customer (KYC) advisers and can provide a detailed analysis to help financial institutions build a profile of an individual customer or entity.

PEP screening

We undertake politically exposed person (PEP) screening to ensure you can assist customers under high scrutiny while still keeping to your compliance obligations.

Adverse media screening

We monitor national and global news and media releases to help institutions track press regarding both individuals and entities.

Who will the AML/CTF rules impact?

These reforms represent a significant shift in Australia’s financial crime prevention landscape and impact both high-risk services and current reporting entities that provide designated services.

From 1 July 2026, AML/CTF obligations will be extended to high-risk services provided by designated non-financial businesses and professions (DNFBPs) or ‘Tranche 2’ entities. The core obligations for these new reporting entities include:

  • Registering with AUSTRAC
  • Conducting customer due diligence (CDD)
  • Assessing and mitigating their business specific AML/CTF risks
  • Reporting suspicious matters and threshold transactions to AUSTRAC.

These new reporting entities include:

Real estate agents are impacted by the reforms when brokering the sale, purchase, or transfer of residential or commercial property. 

The real estate and construction sector is considered a significant channel for money laundering because it allows criminals to move large sums of money through seemingly legitimate, high-value transactions. This not only disguises the origins of illicit funds but can also artificially inflate property prices.

Real estate agents must act by implementing these reforms and undertaking the necessary control measures to protect the integrity of the property market, ensuring that it does not become a vehicle for criminal profit.

Solicitors who provide designated services will become reporting entities with obligations to identify, assess and understand their risk that is unique to their practice. 

For lawyers, the reforms apply to specific designated services such as acting in a property transaction or managing client funds. This presents a unique challenge due to the industry's principles of confidentiality and legal professional privilege.

However, the reforms are designed to work in tandem with these principles with clear protections for privileged information. Lawyers must take action because the transactional, advisory, and confidential nature of their profession makes it a high-risk sector for exploitation by criminals seeking to hide or move illicit funds.

By complying with the new AML/CTF regime, lawyers not only meet a new legal obligation but also uphold their role as officers of the court and prevent their services from being used to facilitate serious and organised crime.

This captures accountants, and trust and company service providers assisting with entity formation, fund management, nominee arrangements, or acting as directors/trustees.

Like lawyers, accountants and trust and company service providers are referred to as ‘gatekeepers’ in the financial system. Accountants are attractive for criminal exploitation because they can create opaque legal structures such as shell companies and trusts that assist criminals in masquerading illicit funds.

The reforms impact accountants by requiring them to implement robust controls when providing certain designated services, such as managing a client's money, accounts, or property, or assisting with the creation of legal arrangements like trusts or companies. 

This is critical as the services provided by accountants are commonly misused to legitimise illicit funds, often through complex corporate structures designed to conceal beneficial ownership.

When left unregulated, accountants can be unwitting conduits for criminal activity. By adopting these measures, they protect their practice's integrity and contribute to the broader effort to prevent financial crime.

This will impact designated services involving AUD$10,000 or more when buying or selling precious metals, stones or products, extending obligations to dealers in these high-value goods. 

The buying and selling of these items, often with large sums of cash or virtual assets, is internationally recognised as a major avenue for money laundering. Such transactions can be used to convert illicit funds into easily transportable and discreet assets.

Dealers are a prime target for criminals seeking to legitimise their earnings. By adopting AML/CTF measures, they can protect their business from financial crime and help law enforcement agencies trace and disrupt criminal networks.

From 31 March 2026, virtual asset services are expanding to capture a broader range of entities, including crypto exchanges, wallet providers, decentralised finance (DeFi) platforms and initial coin offering (ICO) facilitators to combat the misuse of cryptocurrencies and other digital assets for money laundering and terrorism financing.

These reforms are critical to fighting the community harms of crime. The anonymity of virtual assets has been exploited to fund drug trafficking, human smuggling, and scams that devastate lives. 

The primary shift from existing regulations is the expansion of compliance obligations beyond the exchange of virtual assets for fiat currency to now include a wider range of services, such as crypto-to-crypto transfers and the safekeeping of assets.

In addition to acting on core obligations, existing VASPs must implement the ‘Travel Rule’ for certain transfers and register with AUSTRAC.

Current reporting entities:

Current reporting entities must shift from a prescriptive, rules-based approach to a more flexible, risk-based and outcomes-focused framework.

For the gambling sector, a key change is the lowering of the CDD threshold. Businesses must now verify the identity of customers for gaming wins and transfers at a decreased value, down from $10,000 to $5,000.

This requires venues to update their internal procedures to ensure they can efficiently conduct and record these identity verifications for a greater number of transactions, bringing them in line with international standards and strengthening the gaming sector against criminal exploitation.

This reform introduces foundational changes to how banks, credit unions, and other financial institutions manage their obligations. 

They must update their AML/CTF programs to better identify, assess, and manage risks related to money laundering, terrorism financing, and proliferation financing.

A major focus for the sector is strengthening CDD procedures and governance frameworks, with a clear expectation for senior management to take a more proactive role in overseeing compliance.

BDO’s forensic services team supports highly regulated institutions across all sectors to ensure they comply with the AML/CTF Act. Contact our team for assistance with your business’ AML/CTF framework.

Our anti-money laundering insights

Anti-money laundering checklistBDO's anti-money laundering guide and checklist

From 1 July 2026, anti-money laundering and counter-terrorism financing (AML/CTF) obligations will be extended to high-risk services provided by designated non-financial businesses and professions (DNFBPs) or ‘Tranche 2’ entities.

Our anti-money laundering guide and checklist will assist you to understand the changes for your business, identify any potential compliance gaps under the new AML/CTF Act, and start preparing before July next year.

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Alternatively, call 1300 138 991 to speak with an adviser in your nearest BDO office.

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