AML/CTF Obligations

Obligations Under the AML/CTF Act

Complete guide to obligations under Australia's AML/CTF Act. Understand registration, AML/CTF programs, CDD, reporting requirements, and record keeping duties.

Key Information

Understanding Your AML/CTF Act Obligations

Obligations under the AML/CTF Act apply to all reporting entities that provide designated services in Australia. These obligations require businesses to know their customers, monitor for suspicious activity, report to AUSTRAC, and maintain detailed records.

The Act takes a risk-based approach, meaning the extent of your compliance measures should be proportionate to your ML/TF risk profile. However, certain minimum requirements apply to all reporting entities regardless of risk level, including registration, having an AML/CTF program, and meeting reporting obligations.

Key AML/CTF Act Obligations

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AUSTRAC Registration

Reporting entities must enrol with AUSTRAC before providing designated services and maintain accurate enrolment details.

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AML/CTF Program

Develop and maintain a compliant program identifying ML/TF risks and establishing systems and controls.

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Customer Due Diligence

Identify and verify customers, beneficial owners, and assess ML/TF risks before providing services.

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Suspicious Matter Reports

Report suspicious matters to AUSTRAC within specified timeframes when grounds for suspicion exist.

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Threshold Transaction Reports

Report cash transactions of $10,000 or more (or foreign currency equivalent) within 10 business days.

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Record Keeping

Retain customer identification and transaction records for 7 years in accessible format.

Frequently asked questions

What are the main obligations under the AML/CTF Act?

Key obligations include: enrolling with AUSTRAC, developing an AML/CTF program, conducting customer due diligence, ongoing customer due diligence, reporting (SMRs, TTRs, IFTIs), record keeping for 7 years, and appointing a compliance officer.

Who has obligations under the AML/CTF Act?

Reporting entities providing designated services have obligations. Currently this includes financial services, gambling, bullion dealing, and digital currency exchange sectors. From July 2026, lawyers, accountants, real estate agents, and TCSPs also have obligations.

What is a designated service under the AML/CTF Act?

Designated services are specific activities listed in the AML/CTF Act that trigger compliance obligations. Examples include: opening accounts, accepting deposits, making loans, providing remittance services, dealing in digital currency, and (from 2026) certain professional services.

What are the penalties for breaching AML/CTF obligations?

Penalties include: civil penalties up to $5.25 million per contravention for corporations, infringement notices up to $111,000, and potential criminal prosecution for systematic non-compliance or facilitating money laundering.

AML/CTF Act Compliance

ARCaml helps reporting entities meet their obligations under the AML/CTF Act with comprehensive solutions.

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Content sourced from and aligned with AUSTRAC guidance and regulatory requirements.