What have been the key regulatory and enforcement developments in Australia in 2025?
In 2025 and early 2026, there were several notable developments relating to the reforms in the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 (the Amendment Act). These included:
- Several provisions in the Amendment Act commenced, including those that amended the prohibition against reporting entities ‘tipping off’ their customers about certain matters, and those that expanded AUSTRAC's information-gathering powers (including introducing a new examination power).
- AUSTRAC consulted on and published the Anti-Money Laundering and Counter-Terrorism Financing Rules 2025 (Cth) (the New Rules), which will operationalise aspects of the reforms introduced through the Amendment Act.
- It published guidance to support existing and new reporting entities to comply with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (the AML/CTF Act), as amended by the Amendment Act, including toolkits for newly regulated Tranche 2 entities as they prepare for commencement of the AML/CTF reforms.
- It published its expectations for current regulated businesses in progressing to implementing the AML/CTF reforms, including regarding implementation plans (such as the matters that must be addressed in implementation plans, and how these plans will be relevant to AUSTRAC's regulatory activities).
- It advised that it is working with the Department of Home Affairs to finalise transitional rules to support implementation of the AML/CTF reforms—including as to the initial customer due diligence and international transfer of value reporting obligations, with an exposure draft for the transitional rules having been expected to be published in early February 2026 for consultation.
In addition to these reforms-related developments, in December 2025, the Department of Home Affairs commenced consultation on the following proposed changes to the AML/CTF Act:
- to give AUSTRAC new powers to restrict or prohibit high-risk products, services or delivery channels that enable the provision of designated services; and
- to amend the definition of 'terrorism financing' in the AML/CTF Act to give effect to the proposed new offences in the Criminal Code relating to financing of state sponsors of terrorism.
From an enforcement perspective:
- On 30 July 2025, AUSTRAC applied for civil penalty orders against Mount Pritchard and District Community Club Ltd for alleged non-compliance with the AML/CTF laws.
- On 10 December 2025, it applied, in separate proceedings, for civil penalty orders against Castra and Princeton for the alleged failure of each to lodge their respective compliance reports for the 2023 calendar year.
- Its civil penalty proceedings against Entain Pty Ltd and the Star are ongoing, with judgment in the Star proceedings having been expected in early 2026.
- It entered into an enforceable undertaking (EU) with Cryptolink Pty Ltd relating to suspected non-compliance with the AML/CTF laws.
- It issued three infringement notices relating to reporting failures.
- It issued seven notices under subsection 162(2) of the AML/CTF Act, compelling the recipients to engage an external auditor to assess their compliance with the AML/CTF laws.
- It commenced an enforcement investigation in relation to Bendigo and Adelaide Bank's compliance with the AML/CTF laws.
What are the likely regulatory and enforcement developments in Australia in 2026?
We are expecting a number of significant developments in 2026 in relation to AML/CTF regulation and enforcement. In particular:
- Most of the reforms in the Amendment Bill are due to commence in 2026 (subject to any transitional rules), including the provisions that will extend the AML/CTF Act to Tranche 2 entities.
- We understand that AUSTRAC will be making amendments to the New Rules to address feedback from industry.
- In relation to enforcement:
- We anticipate that AUSTRAC will take further enforcement action, particularly against reporting entities in the remittance sector.
- We expect that it will continue to use infringement notices as an enforcement tool in relation to specific non-compliance with the AML/CTF laws.
- While we have not yet seen individuals joined in proceedings against reporting entities or subject to investigations, it is possible that this could occur in 2026.
Who are the key regulators in relation to this area?
The key regulator in this area is AUSTRAC, and for gaming, the state casino and gaming regulators.
AUSTRAC cooperates closely with ASIC, which will often investigate potential breaches of directors' and officers' duties where a major failure in AML/CTF risk management has occurred; as well as with APRA, for entities captured by prudential regulation.
What are the likely regulatory and enforcement developments in Australia in 2026?
The banking, gambling, pubs / clubs and remittance sectors continue to be ongoing focus areas for AUSTRAC's regulatory work.
We anticipate that AUSTRAC will increase its regulatory activities in relation to digital / crypto asset service providers, payment service providers, bullion and non-bank lenders and financiers.
The Amendment Act reforms will also extend AUSTRAC's focus to gatekeeper professions, such as lawyers, accountants and real estate agents.