Anti-Money Laundering

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Money laundering, terrorism financing and proliferation financing pose ongoing risks to Australia’s financial system, economy and national security. Criminals exploit legitimate businesses to conceal illicit funds, support terrorism or enable the spread of weapons of mass destruction, undermining market confidence and exposing organisations to regulatory, legal and reputational risk.

Australia’s AML/CTF framework, established under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, takes a risk-based approach to managing these threats. Australian Transaction Reports and Analysis Centre (AUSTRAC) oversees compliance and uses financial intelligence to detect and disrupt serious and organised crime.

With major reforms taking effect, including expanded coverage from 1 July 2026, organisations face heightened expectations around governance, risk management and compliance. BDO’s AML/CTF Advisory services help clients navigate these changes, meet obligations and implement practical, proportionate frameworks aligned with AUSTRAC expectations.

Money laundering involves disguising the origins of illicit funds, often through complex transactions, structures or cross-border activity.

The impacts of money laundering are far-reaching, fuelling organised crime, terrorism, 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

AML reform timeline

1 July 2026
AML/CTF obligations commence for Tranche 2 entities. Entities should consider testing and review for compliance, remediating any identified issues. Annual reporting period begins.
31 March 2027

If you were enrolled on 30 March 2026 and have already had at least one independent review under the pre-reform rules, you must conduct your first independent evaluation by the later of: 4 years after your most recent independent review, or 31 March 2027.

30 June 2027
Annual compliance reporting period concludes.
30 September 2027
Annual compliance reports are now shifting from calendar year to financial year. For new reporting entities, this means you’ll submit your first compliance report no later than 30 September 2027.
1 July 2029
Newly regulated Tranche 2 entities are required to establish AML/CTF programs that provide for independent evaluations, with the first independent evaluation required within three years, subject to AUSTRAC’s transitional and staggered timing arrangements. Earlier evaluations may be appropriate based on risk profile and business complexity.

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

Our anti-money laundering services


Independent evaluation

Independent evaluation of AML/CTF programs is a mandatory requirement under the AML/CTF Act. BDO provides independent evaluations that go beyond technical compliance to assess whether your AML/CTF framework is effective in practice.

We test whether your program:

  • Reflects your assessed money laundering and terrorism financing risk
  • Meets legislative and AUSTRAC guidance requirements
  • Is implemented and operating as intended
  • Is supported by effective governance, oversight and controls

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

BDO supports small to mid-tier organisations to design, build and review money laundering, terrorism financing and proliferation financing (ML/TF/PF) risk assessments, which form the foundation of an effective AML/CTF program.

AUSTRAC requires reporting entities to maintain a documented, up‑to‑date risk assessment tailored to the nature, size and complexity of their business, covering customers, designated services, delivery channels and jurisdictions, and to use this assessment to shape AML/CTF controls and governance.

AML/CTF uplift and gap assessments

BDO performs AML/CTF gap assessments and uplift reviews for existing reporting entities seeking to enhance the maturity and effectiveness of their AML/CTF frameworks. These engagements identify gaps against current legislative requirements and evolving AUSTRAC expectations, with a focus on control effectiveness, governance, risk assessment quality and operational implementation.

Gap and uplift reviews support organisations to move beyond technical compliance and strengthen their AML/CTF programs in areas such as ML/TF risk assessments, customer due diligence, suspicious matter reporting, training and governance. Outcomes are prioritised to support practical remediation and regulatory risk reduction.

AML/CTF readiness review

BDO helps Tranche 2 entities prepare for AML/CTF regulation commencing 1 July 2026, by assessing readiness against AUSTRAC’s new Act, rules and guidance. We take a practical, service‑specific approach:

  • Tailored to lawyers, accountants, real estate agents and trust and company service providers (TCSPs)
  • Aligned to AUSTRAC’s outcomes‑based regime
  • Focused on proportionate, risk‑based solutions
  • Designed to avoid over‑engineering low‑risk practices.

AML/CTF training and awareness

BDO’s AML/CTF training and awareness service supports organisations to build practical capability, accountability and awareness across their AML/CTF obligations. We design and deliver tailored AML/CTF training for your boards, senior management, compliance teams and frontline staff, aligned to AUSTRAC guidance and your specific ML/TF risk profile. Our training goes beyond generic compliance modules and focuses on how AML/CTF obligations apply in practice and supports effective governance, informed decision‑making and high‑quality regulatory reporting.

Who will the AML/CTF reforms 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:

  • Enrolling 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 Customer Due Diligence (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. 

AML/CTF programs must be updated and uplifted 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 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.

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Contact our team to discuss your needs using the request for service form.
Alternatively, call 1300 138 991 to speak with an adviser in your nearest BDO office.

Meet our team

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Stan Gallo

Leader, Forensic Services
Partner, Forensic Services
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