The Australian Transaction Reports and Analysis Centre (AUSTRAC) has updated its regulatory expectations for businesses already regulated under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 as they transition to new and changed obligations that take effect on 31 March 2026. The update emphasises that regulated businesses must continue to manage money laundering and terrorism financing (ML/TF) risks and comply with core obligations during the transition, and sets out when AUSTRAC expects firms to use implementation plans. Where a business cannot meet its new or changed obligations within the required timeframes from 31 March 2026, AUSTRAC expects a documented implementation plan explaining how ML/TF risks will be managed while changes are delivered. Plans should cover key gaps between current and future state, timelines and accountable roles, reasons for gaps and delivery risks, mitigating controls for temporary or existing ML/TF risk, and how effectiveness will be monitored as systems, policies and processes change; senior management endorsement and provision to the board are expected. AUSTRAC does not require plans to be submitted unless requested, but warns that failures to manage ML/TF risks or meet core obligations can still lead to regulatory action, including civil penalty proceedings and cancellation or suspension of registration for registered businesses. Implementation plans will be relevant to AUSTRAC’s regulatory activities in 2026, with the AUSTRAC CEO expecting to consider whether a business has a reasonable plan, is making sustained effort and progress against it, and is exercising due care and diligence in managing ML/TF risk while transitioning. For businesses that intend to start delivering currently regulated services before 31 March 2026, AUSTRAC recommends building systems and processes to meet the new requirements from the outset and states it will regulate that cohort in line with this recommendation.

Original source View in tracker