AGAMLGURU

Timelines & Transition FAQ

When do AML/CTF obligations start for newly regulated firms?

For newly regulated firms, AUSTRAC says the reformed AML/CTF obligations commence on 1 July 2026. AUSTRAC also says enrolment opened on 31 March 2026, and newly regulated businesses must make sure they are enrolled by 29 July 2026.


Are there transitional rules for newly regulated AML/CTF reporting entities?

Yes. Transitional rules have been introduced to help newly regulated businesses move into compliance with the AML/CTF regime.

These rules recognise that businesses such as real estate agents, accountants, lawyers and conveyancers are being regulated for the first time and may need time to fully implement their compliance frameworks.


When do the AML/CTF obligations start under the transitional rules?

The new AML/CTF obligations for newly regulated entities commence on 1 July 2026. From this date, businesses providing designated services are expected to comply with the AML/CTF Act and Rules.


What does AUSTRAC expect newly regulated firms to have in place by 1 July 2026?

AUSTRAC says that by 1 July 2026 newly regulated entities should be enrolled as reporting entities, have an AML/CTF program, appoint an AML/CTF compliance officer, train staff on the program and internal processes, and be ready to engage with clients and report suspicious matters.


Do we need to be fully compliant on day one?

AUSTRAC has indicated that it does not expect perfection from newly regulated entities immediately. However, businesses are expected to:

  • Take reasonable steps to comply
  • Have a clear implementation plan
  • Demonstrate genuine and proactive efforts
  • Begin operating in line with AML/CTF obligations

Failure to make reasonable progress may still result in regulatory action.


When do we need to enrol with AUSTRAC?

Enrolment for newly regulated entities opened on 31 March 2026, and businesses must ensure they are enrolled by 29 July 2026 if they provide designated services.


When do we need to appoint and notify a compliance officer?

You must appoint an AML/CTF compliance officer and notify AUSTRAC by the later of:

  • 14 days after enrolment, or
  • 29 July 2026

Can we phase the implementation of our AML/CTF program?

Yes. The transitional approach allows businesses to progressively build and implement their AML/CTF program. However, key elements should be in place early, including:

  • Risk assessment
  • Basic customer due diligence processes
  • Staff awareness and training
  • Ability to identify and report suspicious matters

Are there any obligations that must be met immediately from 1 July 2026?

Yes. Even during the transition period, businesses are expected to:

  • Enrol with AUSTRAC
  • Begin applying customer due diligence
  • Identify and report suspicious matters
  • Start operating their AML/CTF program

What happens if we delay compliance during the transition period?

While AUSTRAC takes a supportive and risk-based approach, businesses that delay without reasonable justification or fail to demonstrate progress may face enforcement action.


What is AUSTRAC's approach during the transition period?

AUSTRAC has stated that it will take a risk-based and proportionate approach, focusing on whether businesses are engaging with obligations and addressing higher-risk areas first.


What should we prioritise during the transition period?

Newly regulated businesses should prioritise: understanding whether they provide designated services, enrolling, building an AML/CTF program, training staff, and establishing initial CDD and reporting processes.