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Tranche 1 AML/CTF Reforms for existing Reporting Entities

If you are an Australian Tranche 1 business (ie, an existing Reporting Entity), you have an obligation to implement the updated AML/CTF regime by 31 March 2026.

We can help!

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We can help to re-align your existing AML/CTF Compliance Framework to the new requirements. Contact us via the Contact Us page or book a consultation

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For reference and self-help, this page provides relevant resources in helping you understand and implement the new AML/CTF requirements. We will keep adding more content and resources to this page in the run-up to the new regime. So do bookmark the page!


Please reach out to us if you have a question or need support in implementing the new regime. 

FAQs

  • Understanding correctly the scope of Designated Services for your business - refer here.

 

  • 'Reporting Group' under the new AML/CTF regime - refer here.

 

  • Appointing an AML/CTF Compliance Officer for your business - refer here.

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  • Engaging an AML/CTF Adviser for advisery services - refer here.

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Key Dates

If you are Tranche 1 designated services provider, know key compliance dates - refer below

Resources - Read our AML/CTF reforms and Tranche 2 related Blogs

Read our ​blogs on AML/CTF reforms - click here.​​

Regulatory Resources

Key regulatory resources relevant for you - click here.​

Key Dates

I.  Existing Reporting Entities (For DCEs, refer section II below)

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If you are an existing provider of designated services (ie you already comply with the AML/CTF Act ):

 

​Your compliance deadline is - 31 March 2026 (this is subject to the Transitional Rules from AUSTRAC)  

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  • The new AML/CTF regime applies for your business from 31 March 2026

  • You must start complying with the updated AML/CTF obligations from 31 March 2026. This means your AML/CTF compliance framework should be ready by this date and go live

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​What does readiness means?

  • Updated the Money Laundering / Terrorist Financing / Proliferation Financing Risk Assessment in line with the new requirements

  • Revised your AML/CTF Compliance framework comprising program and related policies, in line with the updated legislation 

  • Taken steps and readiness in place to operationalise the compliance program and framework.

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It also involves:

  • Designated an AML/CTF Compliance Officer (Under Transitional Rules, a RE can notify AUSTRAC by 30 June 2026). 

  • Undertaken relevant AML/CTF training for your staff.​​

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II. Virtual Asset Service Provider Businesses

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For businesses registered with AUSTRAC as a Digital Currency Exchange (DCE) as on 31 March 2026, your business will be re-categorised as a Virtual Asset Service Provider.

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​​Your compliance deadline - 31 March 2026 (Transitional Rules have extended this to 30 June 2026). 

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  • The new AML/CTF regime applies for your business from the date mentioned above.

  • You must start complying with the updated AML/CTF obligations from this date. This means your AML/CTF compliance framework should be ready by this date. 

  • While initially, the legislation required all existing DCEs to re-register their businesses before the above date, the Transitional Rules proposed have removed this restriction. 

  • All new VASP businesses (which includes DCEs) must register themselves with AUSTRAC before providing designated services. 

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Virtual Asset Services provided in the course of a business that are registrable include:

  • exchanging virtual asset for money; money for virtual asset; and virtual asset for another virtual asset

  • providing another designated service in connection with the offer or sale of a virtual asset

  • providing a virutal asset safekeeping service

  • Remitting or receiving remittance of funds, where this involves virtual asset.

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What does readiness means?

  • Undertaken a Money Laundering / Terrorist Financing / Proliferation Financing Risk Assessment

  • Developed and implemented an AML/CTF Compliance framework comprising program and related policies

  • Taken steps and readiness in place to operationalise the compliance program and framework.

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It also involves:

  • Designated an AML/CTF Compliance Officer

  • Undertaken relevant AML/CTF training for your staff.​​

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Our Blogs on AML/CTF reforms and Tranche 1, and other related blogs

AML/CTF reforms and Tranche 2 related blogs:​​

  • Updated AML/CTF Act implementation - Some key pointers - click here

  • Tranche 2: Modernising and simplifying Australia's AML/CTF regime - click here

  • AML/CTF Amendment Bill - Towards a stronger AML/CTF regime - click here.

 

Other blogs by us, that are relevant read:

  • ​AUSTRAC's Regulatory prioirites for 2025-26 - click here

  • AML & FCC developments in 2024 - click here

  • Suspicious activity indicators for designated service providers - click here

  • Australia's ML/TF National Risk Assessments - click here

  • Thematic Sanctions - click here

  • AUSTRAC Guidance on Data Breaches - click here

  • Failure to enrol your business as a reporting entity - click here.

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Regulatory Resources

Key regulatory resources relevant for your compliance efforts:

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  • AML/CTF Act (Future compilation, for the new regime) - click here

  • AML/CTF Rules (updated for the new regime) - click here

  • AUSTRAC's reforms related resources page - click here

  • AML/CTF Transitional Rules - click here

  • Risk Assessments - click here (includes National and Sectoral risk assessments).

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Compliense Advisors is an AML/CTF and FinCrime compliance and risk management advisory firm.
Our experience includes implementing legislative changes; undertaking ML/TF risk assessment; setting up, implementing, uplifting AML/CTF program; and advising on AML/CTF and FinCrime compliance and risk matters.

 

The contents above is for general awareness and informational purposes only. Please carefully evaluate your circumstances, and seek professional advice for your specific needs. You are responsible for your compliance obligations, and for any action taken or omitted. We are not a law firm, and do not provide legal advice.

 

Write to us on compliense@compliense.com.au. Visit here for more such knowledge resources. You can also sign up for new articles and updates
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