Anti Money-Laundering Law Australia
Summary
Astris Law advises Australian reporting entities on AML/CTF compliance under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth). Services include AUSTRAC registration, AML/CTF program development, suspicious matter reporting, enforcement defence and Tranche 2 readiness for lawyers, accountants, real estate agents and other designated services from 2026.
Overview
Australia's AML/CTF regime has applied to financial services, gambling and bullion dealers since 2006. Reporting entities in these sectors have operated under AUSTRAC oversight for nearly two decades, managing program obligations, transaction reporting and customer due diligence as part of day-to-day operations. Astris Law assists these entities with compliance, remediation and regulatory defence.
From 2026, Tranche 2 extends the regime to lawyers, accountants, real estate agents, TCSPs, virtual address providers, precious metals and stones dealers, property developers, business brokers and other designated service providers. These entities will become reporting entities for the first time, requiring AML/CTF programs, AUSTRAC registration and ongoing compliance frameworks.
Whether an established reporting entity or a Tranche 2 entrant, Astris Law treats AML/CTF as a core operational risk, not an isolated compliance exercise. We build pragmatic, defensible programs that satisfy regulatory expectations without paralysing commercial operations.
How We Help
Astris Law is one of a small number of Australian law firms with a dedicated AML/CTF compliance practice. We advise Brisbane businesses and reporting entities on every aspect of their obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, from initial AUSTRAC registration and AML/CTF program development through to enforcement defence and remediation.
For existing reporting entities in financial services, gambling and bullion dealing, we review and strengthen AML/CTF programs, advise on suspicious matter reporting and threshold transaction obligations, conduct independent evaluations and respond to AUSTRAC investigations and enforcement action. Our programs are designed to be operationally practical, not just legally compliant on paper, so that your frontline staff can implement them consistently. For Brisbane businesses facing AUSTRAC audits or compliance concerns, we provide rapid assessment and remediation support.
From 2026, the AML/CTF regime extends to lawyers, accountants, real estate agents, trust and company service providers, precious metals and stones dealers, property developers and other designated services under Tranche 2. These entities will become reporting entities for the first time, requiring AML/CTF programs, AUSTRAC registration and ongoing compliance frameworks.
Common Situations
- Your business is a reporting entity and AUSTRAC has commenced an investigation or issued an infringement notice
- You need an AML/CTF program developed, reviewed or remediated to meet current AUSTRAC expectations
- Your compliance team has identified a suspicious matter and you need advice on reporting obligations and timeframes
- Your business provides designated services and needs to prepare for Tranche 2 AML/CTF obligations from 2026
- You are undergoing an independent evaluation of your AML/CTF program and need legal support
- Your board or senior management need training on AML/CTF governance obligations and escalation protocols
Why Astris Law
Astris Law is one of a small number of Brisbane firms with a dedicated AML/CTF practice. You get direct principal access on every matter, which is critical when AUSTRAC deadlines are running and compliance failures carry serious penalties.
What We Can Do
Our Special Interests
Key Legislation & Frameworks
Frequently Asked Questions
What is an AML/CTF program and do I need one in Australia?
An AML/CTF program is a compliance framework required under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) for all reporting entities. It must include customer identification procedures, ongoing customer due diligence, transaction monitoring and suspicious matter reporting processes. If your business provides designated services including financial services, gambling, bullion dealing or (from 2026) professional services under Tranche 2, you are required to have an AML/CTF program registered with AUSTRAC.
What is Tranche 2 AML and when does it start in Australia?
Tranche 2 extends Australia's AML/CTF regime to lawyers, accountants, real estate agents, trust and company service providers (TCSPs), precious metals and stones dealers, property developers, business brokers and other designated service providers. These entities will become reporting entities for the first time, requiring AML/CTF programs, AUSTRAC registration and ongoing compliance frameworks from 2026.
What happens if my business fails to comply with AUSTRAC obligations?
Non-compliance with AUSTRAC obligations can result in significant civil penalties, infringement notices, enforceable undertakings and, in serious cases, criminal prosecution. AUSTRAC has the power to conduct investigations, impose remedial directions and pursue Federal Court proceedings for systemic compliance failures.
What is a suspicious matter report (SMR) and when must I lodge one?
A suspicious matter report must be lodged with AUSTRAC when a reporting entity forms a suspicion on reasonable grounds that a transaction or activity may be related to money laundering, terrorism financing, tax evasion or proceeds of crime. SMRs must be submitted within 24 hours for terrorism-related matters and within 3 business days for all other suspicious matters. Failure to report is a criminal offence.
How can a lawyer help with an AUSTRAC investigation?
A lawyer experienced in AML/CTF matters can help you respond to AUSTRAC investigation notices, prepare submissions, manage document production, negotiate enforceable undertakings and represent you in Federal Court proceedings. Early legal advice can help contain the scope of an investigation and protect your business from escalating penalties.
Insights & Publications
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AML Tranche 2 Starts in Three Weeks. Here Is What We Have Been Building.
10 June 2026
For the past year we have been building for Tranche 2. More than 2,500 pages of policy documents, risk assessments and procedures across twelve sector editions, published through HeadStart Docs™. A compliance portal of roughly 410,000 lines of code behind them. A dedicated Tranche 2 advice practice, HeadStart Counsel, the trading name under which Astris Law does this work. This article announces that work, lists the sectors we built for and shares what the work taught us, because the questions reaching us in the final weeks before commencement have answers that nobody else is publishing.
Read more
Astris Law Launches HeadStart Counsel for Tranche 2
28 May 2026
Astris Law has launched HeadStart Counsel, its Tranche 2 legal practice and the legal advisory arm to the HeadStart Docs™ compliance platform. From 1 July 2026 the AML/CTF regime extends to an estimated 80,000 to 100,000 new Australian businesses, and HeadStart Counsel exists to answer the are-we-in-or-are-we-out question, the edge cases and the questions with no published authority.
Read more
Suspicious Matter Reporting to AUSTRAC: When Australian Businesses Must File
21 May 2026
Suspicious matter reporting is the obligation businesses most often get wrong, usually by reporting too late or saying too much to the customer. This article sets out when you must file a suspicious matter report with AUSTRAC, the deadlines that apply and the confidentiality rules that let you report without alerting the customer.
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Dedicated legal counsel for casinos, online wagering operators and gaming technology providers.
Need a anti money-laundering lawyer? Talk to Astris Law.
We work directly with our clients on anti money-laundering matters across Australia. No layers, no committees.