Helping you meet your AML/CTF obligations with confidence
Wherever you are on your AML/CTF journey, we can tailor a risk-based, regulator-ready solution designed to protect your business and support sustainable growth.
At Source, our AML/CTF specialists support organisations at every stage of their compliance journey – from refreshing existing risk assessments to designing and implementing fully operational compliance frameworks. Discover how Source can support you.
What are the AML/CTF regulations?
Australia’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) reforms represent one of the most significant regulatory expansions in over a decade. In July 2026, the regulatory obligations are expanding to include additional professional industries. If your business operates in accounting, legal services, real estate, trust and company services, or high value goods (such as jewellers), the reforms may directly impact you.
These reforms are designed to strengthen oversight and tighten controls to mitigate against the risks of money laundering and terrorism financing within industries that are often susceptible to this type of criminal activity.
Accounting
Legal Services
Real Estate
Trust and Company Services
High value goods (eg. jewellers)
What are your obligations?
The regulator (AUSTRAC) is expected to place significant supervisory focus on these newly regulated industries and will expect clear evidence of documented preparation, governance oversight and demonstrable ML/TF risk assessment processes.
For businesses now covered by these regulations, you may be required to:
- Monitor higher risk clients and transactions
- Submit suspicious matter reports where required
- Maintain detailed record-keeping procedures
- Prepare for independent review requirements
- Embed a documented risk-based approach across operations
- Enrol with AUSTRAC
- Develop and maintain a documented, risk-based AML/CTF Program
- Appoint an AML/CTF Compliance Officer
- Conduct customer due diligence, including verification of beneficial ownership
- Ensure Board and senior management oversight of AML/CTF compliance
Specific considerations for different business types
Understanding how the reforms intersect with your specific service offering is critical.
Corporate structuring, trust arrangements and cross border advisory exposure can elevate inherent ML/TF risk and require enhanced due diligence and governance oversight.
Property transactions remain a primary channel for money laundering risk, particularly where third party payments, complex settlement arrangements or opaque ownership structures are involved.
Corporate layering, nominee arrangements and international exposure increase regulatory scrutiny and documentation expectations.
Cash intensive and high value transactions require carefully calibrated monitoring controls and robust record keeping frameworks.
How we can help
Our team of compliance specialists work with businesses to develop practical, proportionate solutions designed to keep you compliant without holding up your business in compliance red tape. We deliver practical outcomes for your business – that means tailored compliance programs embedded in your business, not just the theory.
Enterprise-wide Risk Assessments
We conduct structured ML/TF risk assessments aligned to AUSTRAC expectations, identifying exposure, control effectiveness and practical remediation priorities tailored to your business model.
AML/CTF programs
We’ll work with you to design and implement tailored, risk-based AML/CTF Programs that are operationally embedded, regulator ready and aligned to your broader governance framework.
Regulatory reporting and ongoing support
We support suspicious matter reporting, AML/CTF Compliance Officer advisory needs, training programs and independent review readiness to ensure continued compliance.
Need support?
Our team is here to help you with your compliance questions.
Get in touch with us today and someone from our team will be in contact.
Why work with Source?
Our compliance leaders bring deep AML reform expertise and practical implementation experience across both established reporting entities and newly captured Tranche 2 businesses. We deliver proportionate, regulator-aligned solutions that are embedded within your operations, not just policy documents.
Resources
Stay informed with practical insights and resources.
Frequently Asked Questions
If you’re unsure how the reforms apply to your business, our team can assist with an initial readiness discussion.
The reforms expand obligations to designated services in sectors including:
• Accountants and Tax Agents
• Law Firms
• Real Estate Agents and Conveyancers
• Trust and Company Service Providers
• Dealers in High-Value Goods
If you provide designated services, you may need to enrol with AUSTRAC and implement an AML/CTF Program.
A documented, risk-based compliance framework addressing:
• Governance arrangements
• Money Laundering/Terrorism Financing risk assessment
• Customer due diligence
• Ongoing monitoring
• Reporting obligations
• Compliance oversight
Yes.
Section 81 of the AML/CTF Act requires reporting entities to designate an AML/CTF Compliance Officer.
The officer must have:
• Appropriate seniority
• Authority to implement the Program
• Access to resources
• Direct reporting lines to senior management
The appointment must be formally documented.
Notification is required only if enrolment information changes.
Under section 51B of the AML/CTF Act, AUSTRAC must be notified within 14 days if:
• A new AML/CTF Compliance Officer is appointed
• The officer’s name or contact details change
• Enrolment information previously provided changes
If the same individual remains appointed and details have not changed, notification is not required simply due to updated competency expectations.
Internal documentation should confirm ongoing compliance.
• Civil penalties
• Enforceable undertakings
• Public regulatory action
• Increased regulatory visibility and supervisory engagement
• Personal accountability for senior officers
• Operational disruption and reputational impact
Regulators expect documented preparation and governance oversight.
• Confirm whether designated services apply
• Conduct a gap assessment
• Identify an AML/CTF Compliance Officer
• Review governance oversight
• Update policies and procedures
• Train staff where required
Early preparation reduces operational disruption and regulatory risk. Get in touch with the Source team for a no-obligation discussion on how we may be able to support you with these actions.
Get in touch
Book a confidential AML/CTF readiness discussion with one of our compliance experts.
DISCLAIMER
These FAQs are intended for general information and thought leadership purposes only and do not constitute legal, compliance or regulatory advice. It is also not intended to function as formal training or continuing professional development material.
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