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    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. Astris Law delivers Tranche 2 readiness through HeadStart Counsel, a dedicated service designed to guide new reporting entities through the transition.

    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.

    HeadStart Counsel

    Our dedicated Tranche 2 readiness service for all designated services - including lawyers, accountants, real estate agents, TCSPs, precious metals dealers, property developers and more - preparing for AML/CTF obligations from 2026.

    Visit HeadStart Counsel

    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. Astris Law delivers Tranche 2 readiness through HeadStart Counsel, a dedicated onboarding service that takes new reporting entities from zero to compliant with their AML/CTF program, AUSTRAC registration and ongoing obligations.

    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 — critical when AUSTRAC deadlines are running and compliance failures carry serious penalties.

    What We Can Do

    AML/CTF program development, review and remediation
    AUSTRAC registration, reporting entity obligations and ongoing compliance
    Suspicious matter reports, threshold transaction reports and IFTI obligations
    AUSTRAC investigations, infringement notices and enforcement responses
    Independent evaluations under the AML/CTF Act
    Board and senior management AML/CTF training and governance frameworks
    Transaction monitoring systems, customer due diligence and KYC frameworks
    Correspondent banking relationships and enhanced due diligence programs
    Tranche 2 readiness and onboarding

    Our Special Interests

    Responding to AUSTRAC investigations and enforcement action
    Designing risk-based AML/CTF programs for complex business models
    Managing remediation programs following compliance failures
    Navigating cross-border AML obligations and correspondent banking requirements
    Preparing Tranche 2 entities - including lawyers, accountants, real estate agents, TCSPs, precious metals dealers, property developers and business brokers - for AML/CTF obligations from 2026

    Key Legislation & Frameworks

    Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth)AML/CTF RulesFinancial Transaction Reports Act 1988Autonomous Sanctions Act 2011Charter of the United Nations Act 1945

    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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    Reforms to the ASCR Following AML Tranche 2 Reforms - Astris Law legal insights
    Publication

    Reforms to the ASCR Following AML Tranche 2 Reforms

    8 March 2026

    The Law Council proposes amending Rule 8 to accommodate AML/CTF obligations. We submit that if Rule 8 is amended, Rule 12 must also be addressed and that the deeper question is whether ethical rules should bend to match new legislation or whether the legislation should be measured against the ethical framework it displaces.

    Read more
    AUSTRAC Free Starter Kits: How Did They Rate? - Astris Law legal insights
    Insights

    AUSTRAC Free Starter Kits: How Did They Rate?

    25 February 2026

    We assessed the AUSTRAC free starter kits against the mandatory requirements in the AML/CTF Act 2006 and AML/CTF Rules 2025. Overall they rate well. Here is what they got right and where they fell short.

    Read more
    Astris Law Speaks at DECA Digital Economy Conference 2025 - Astris Law legal insights
    News

    Astris Law Speaks at DECA Digital Economy Conference 2025

    18 June 2025

    Astris Law joined speakers from Kraken and Thomson Geer at the Gold Coast for the DECA Digital Economy Conference 2025, discussing the evolving regulatory landscape for digital assets in Australia.

    Read more

    Industries We Serve in Anti Money-Laundering

    Banking, Private Equity & Venture Capital

    Strategic legal counsel for banks, private equity firms and venture capital funds.

    Fintech

    Innovative legal solutions for payment platforms, neobanks and financial technology disruptors.

    Gambling

    Specialist legal counsel for casinos, online wagering operators and gaming technology providers.

    Written by Jamie Nuich, Principal of Astris Law

    Need a anti money-laundering lawyer? Talk to Astris Law.

    We work directly with directors on anti money-laundering matters across Australia. No layers, no committees. One lawyer who understands your business completely.

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