A leading anti-money laundering expert has warned that AUSTRAC will not mess around when it comes to enforcing the incoming AML/CTF regulations for accountants, lawyers and real estate.

Nathan Lynch, financial crime writer and AML specialist, said AUSTRAC has already shown it won’t hesitate to take action.

However, the good news is that compliance is entirely achievable by mid-2026 – if businesses start preparing now.

"AML/CTF civil enforcement cases in Australia have already resulted in over $2.5 billion in penalties. We’ve also seen ASIC take action against directors personally, such as in the Star case," said Lynch.

In November, AUSTRAC launched civil penalty proceedings against The Star Pty Limited and The Star Entertainment QLD Limited, citing serious and systemic AML/CTF failings.

“So the message is clear: this is not an aspect of regulation where organisations can afford to be complacent,” he said.

Australia has seen high-profile enforcement cases against casinos, banks, and betting firms. Now, with Tranche 2 reforms set to take effect by mid-2026, accountants, lawyers, and real estate professionals will be in the spotlight.

However, the news is not all bad, as Lynch said AUSTRAC is a “very collaborative regulator” and wants to support businesses to ensure they are able to provide the best possible financial intelligence.

“This is not about catching you out for technical compliance failures, it’s about making your organisation better and part of the national partnership to fight serious and organised financial crime, including the country’s $2 billion-per-year scams problem”, Lynch said.

What businesses should be doing right now

The AML/CTF regime will extend to more than 70,000 businesses – many of them SMEs – introducing new risk assessments, reporting obligations, and compliance frameworks. While AUSTRAC is still refining guidelines, Lynch explained that there are critical steps businesses can take today.

“The key lesson from overseas is not to leave your run too late. For those that get started now, the mid-2026 deadline is very achievable”, said Lynch.

Start your risk assessment now – “a fundamental prerequisite for understanding your organisation’s risk appetite and developing systems and controls”, explained Lynch.

Appoint internal compliance leaders – “designate people within your organisation who can take responsibility for key roles and delivering on your milestones over the next 18 months”.

Engage your board – “It’s crucial at this stage to make sure the board is involved, interested and setting the tone from the top. As recent enforcement cases involving Australian casinos and banks have shown, AUSTRAC will really want to see that the board is taking this issue seriously.”

Don’t rely on consultants last-minute – Demand for compliance advisers will skyrocket as deadlines approach so “get the right advice early in the piece”.

Join the experts who are leading Australia’s AML compliance

Lynch and over 25 financial crime, legal and regulatory experts, including AUSTRAC, will be speaking at AML Edge 2025, taking place this Thursday, 27 March, at Watersedge, Sydney.

This is your opportunity to hear directly from those shaping AML policy and enforcement in Australia. Don’t wait until the last minute – get ahead of the reforms now.

Last tickets remain – secure yours today at www.amledge.com.au.