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22 May 2024

AML/CTF Reforms Are Coming: What You Need to Know Before 2026

Manisha Reddy

Australia is on the brink of one of its most significant Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) reforms in over a decade. With new obligations coming into effect for both current and new reporting entities, now is the time for businesses and the professionals who support them to assess readiness and act.

At GRC Talent, we are already seeing an increase in demand for AML/CTF professionals with the expertise to guide businesses through this transformation.

Whether you are a risk and compliance officer, an AML analyst, or an in-house legal counsel, these changes could shape the compliance landscape and your career trajectory over the next few years.

What’s Changing?

The Australian Government is reforming the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, with new obligations commencing on:

31 March 2026 – for current reporting entities

1 July 2026 – for tranche 2 entities (including lawyers, accountants, real estate agents, and jewellers)

These reforms aim to bring Australia in line with international standards and close long-standing regulatory gaps, particularly in high-risk professional services.

Source: AUSTRAC (2025), www.austrac.gov.au

Expectations for Current Reporting Entities

If you are already a reporting entity, AUSTRAC expects you to maintain your existing AML/CTF controls while actively preparing for the new legislative requirements.

This includes:

- Continuing to implement current controls against money laundering and terrorism financing

- Developing and documenting a transition plan for reforms under the new AML/CTF Act

- Making consistent progress in implementing these plans

- Strengthening internal frameworks and systems proactively

- Managing risks continuously - even during the reform phase

AUSTRAC is especially concerned about entities with weak or outdated controls. If your systems are ineffective or if you’re ignoring your obligations, you’re already on regulatory notice. This is not just a future issue - non-compliance is a serious concern today and will carry even more weight post-reform.

Expectations for Tranche 2 Entities

For professionals and firms in legal, accounting, real estate, or jewellery sectors, the countdown is on. If you are part of this 'tranche 2' group, you will need to be fully compliant by 1 July 2026.

Here's what AUSTRAC expects by that date:

- Enrolment as a reporting entity (opens 31 March 2026)

- A fit-for-purpose AML/CTF Program (starter templates available from December 2025)

- Appointment of a Compliance Officer

- Staff training on AML/CTF obligations

- Ability to report suspicious matters

Failure to enrol or blatant non-compliance will place your business and your reputation at risk. AUSTRAC has made it clear: enforcement actions will be prioritised against entities that wilfully ignore or enable money laundering.

What This Means for GRC Professionals

This reform is not just a legal or operational change. It's a career opportunity. We are already seeing some increased hiring activity for roles such as:

- Head of AML

- AML Compliance Officer

- AML Analysts

- Legal professionals with regulatory reform backgrounds

Now is the time to upskill, reskill, or reposition your expertise. Demand is only set to rise as we approach 2026.

How Can You Prepare?

- Employers already captured by Tranche 1: Start your internal readiness reviews now. Engage AML/CTF professionals to help build or strengthen your compliance programs.

- Newly captured Tranche 2 reporting groups: Seek advisory support or specialist consultants to help you onboard AML/CTF requirements before they become enforceable.

- Candidates: Build expertise in AML/CTF legislation, AUSTRAC compliance frameworks, and financial crime risk assessments. Certifications like ACAMS or ICA can help you stand out.

Final Thoughts

The upcoming AML/CTF reforms are more than a compliance update, they are a chance to build better business resilience, demonstrate ethical governance, and elevate Australia's global financial integrity. For those in the GRC space, this is your call to step forward and lead the way. Whether you're hiring or looking for your next opportunity, GRC Talent is here to help you navigate what’s next.

To stay updated on reform news, job opportunities, and insights, connect with us on LinkedIn or reach out at hello@grctalent.com.au

By Manisha Reddy | GRC Talent Blog

Citing AUSTRAC | www.austrac.gov.au