Updates to AML/CTF Rules: New requirements for AML/CTF regime

Australia’s anti‑money laundering and counter‑terrorism financing (AML/CTF) regime is moving into a new phase. In 2024 and 2025, Parliament passed major changes to the AML/CTF laws, which set up a new framework for how the regime will operate. The ‘Tranche 2’ reforms, which expand the range of services and types of organisations captured by AML/CTF obligations, will commence from 1 July 2026.[1]

Supporting the legislative changes introduced by the new AML/CTF regime, AUSTRAC issued new Rules[2] which were tabled in Parliament in August 2025. Shortly before the Rules were due to take full effect on 31 March 2026, AUSTRAC made further changes to address minor issues, improve the effectiveness of the Rules, and simplify compliance obligations – particularly for corporate groups.[3]

This article provides an overview of the key changes introduced by the amendments to the Rules that reporting entities should be aware of to ensure compliance with the new AML/CTF regime.

Why were the Rules amended?

AUSTRAC rewrote the AML/CTF Rules in 2025 to support changes to the AML/CTF Act[4] that update and expand the regime. Before the Rules took effect, AUSTRAC made targeted changes to address minor issues. These further changes are aimed at ensuring the reforms are fully operational before a significant expansion of the regime from 1 July 2026.

The key changes to the Rules include:

• Automatic (opt‑out) reporting groups;
• Clarifications to customer due diligence;
• Travel Rule amendments;
• Annual compliance reporting;
• Enrolment and registration changes; and
• Certain new exemptions.

The Biggest Change - Automatic Reporting Groups

The new AML/CTF reforms allow related companies in a corporate group to be treated as a single ‘reporting group’. One company can be appointed as the ‘lead entity’ to report to AUSTRAC on behalf of the group. Under the original Rules, companies had to formally notify AUSTRAC if they wanted to set up a reporting group.

Now, the amendments introduce a new ‘opt-out’ reporting group model, where related entities in a corporate group/control structure are automatically treated as a reporting group by default, unless a reporting entity formally notifies AUSTRAC that they will not be a part of that group (in which case they must comply with all obligations separately).

This is intended to make it easier for business groups to be treated as a reporting group without having to go through a complex setup process.

Customer Due Diligence

The changes also clarify the Rules around verifying a customer’s identity (often called ‘know your customer’ or ‘KYC’ checks).

In particular, certain changes have been introduced in relation to the provision of real estate services.

Real estate agents now have 28 days (up from 15 days) to verify identity information that was already collected by another party in the same transaction, and must do so at least 3 days before the agreed settlement date.

There is also a new process for situations where a customer of a real estate brokering service does not cooperate with identity verification. In these cases, a reporting entity is taken to have met its customer due diligence obligations provided it has:

• taken all reasonable steps to verify the identity;
• recorded the difficulties encountered; and
• considered whether a suspicious matter report should be made.

Travel Rule Amendments

AUSTRAC has amended the requirements around information which must be transmitted regarding a payer and payee, which is known as the ‘travel rule,’ by extending the exemption that allows certain customer information (such as the payer’s address) not to be verified.

This exemption now applies to all customers for transactions conducted before 1 July 2030. The change recognises that businesses need time to update their systems and processes before full implementation.

Cryptocurrency and digital asset businesses (known as virtual asset service providers, or VASPs) are not covered by this relief and will need to comply with the travel rule from 1 July 2026.

Annual Compliance Reporting

Previously, the 2025 Rules provided that each calendar year is a reporting period for the purposes of AML/CTF compliance reporting.

Now, the deadline for annual compliance reports has been aligned with the Commonwealth’s broader reporting calendar, with the first reporting period commencing on 1 July 2026 and ending on 30 June 2027.

New Exemptions

Some businesses have been given relief from certain customer identity checks.

For example, reporting entities do not need to carry out initial identity checks for one‑off ATM withdrawals of cash where the total amount is less than $10,000.

Similar relief applies to one‑off transactions involving digital assets. Reporting entities do not need to verify a customer’s identity where less than $1,000 worth of digital assets is transferred to a personal (self‑hosted) wallet.

Businesses that issue gift cards are also exempt from initial identity checks for one‑off transactions using the card, as long as safeguards are in place. These include limits such as the card’s value not being increased and the stored value not being withdrawn as cash.

Some groups that were never meant to be covered by the AML/CTF rules have also been formally exempted. These include community legal centres and legal aid commissions, barristers acting for Australian government bodies, and operators of clearing and settlement facilities.

What should businesses do now?

Businesses already regulated by AUSTRAC should stay up to date and review how these changes affect their identity checks, group reporting arrangements and compliance calendars.

Businesses newly covered by the AML/CTF regime should start building compliance programs as soon as possible to be on track for the new rules from 1 July 2026.

What are the Cleardocs products available?

Cleardocs offer the following relevant products:

• Register a Company
• Change to Constitution
• Company Minutes & Resolutions Package
• Superannuation Trust (SMSF)
• Discretionary (Family) Trust
• Discretionary Trust - Excluded Beneficiaries
• SMSF Set Up + Register Corporate Trustee

Please read the Product Benefits, Product Information and Frequently Asked Legal Questions carefully and consider if it is appropriate in your circumstances before purchasing any Cleardocs product.

More information from Maddocks

For more information, contact Maddocks on (03) 9288 0555 and ask to speak to a member of the Commercial team.

More Cleardocs information on related topics

• AML/CTF reforms for Tranche 2 entities: what accountants and lawyers must be ready for by 1 July 2026
• From Exemption to Expectation: Anti-Money Laundering’s Professional Turn
• Discretionary Trust Deeds For Family Trusts - Aren't They All The Same?
• A 2025/1 - Managed Investment Trusts: Restructures To Access The MIT Withholding Regime
• Update For SMSF Trustees: ATO Enforcement Actions For Non-Compliance

[1] See our previous ClearLaw article: AML/CTF reforms for Tranche 2 entities: what accountants and lawyers must be ready for by 1 July 2026.

[2] Anti-Money Laundering and Counter-Terrorism Financing Rules 2025 (Rules).

[3] Anti‑Money Laundering and Counter‑Terrorism Financing (2025 Rules) Amendment Rules 2026 (Cth) and Anti‑Money Laundering and Counter‑Terrorism Financing (Class Exemptions and Other Matters) Amendment Rules 2026 (Cth).

[4] Anti‑Money Laundering and Counter‑Terrorism Financing Act 2006 (Cth) and (AML/CTF Act).