AUSTRAC’s 2026 AML/CTF reforms apply to AFSL holders and authorised representatives when they provide designated services, particularly where advice extends into arranging, dealing, implementation, or other regulated transaction activities. Pure strategic advice is generally not captured. Obligations arise when advisers help execute transactions, move assets, or provide other designated services beyond advice alone.
Expanded Answer
The 2026 AML/CTF reforms expand AUSTRAC’s oversight of professional services and bring many financial advice businesses into the AML/CTF framework where they provide designated services. The key distinction is not whether an adviser provides financial product advice, but whether the adviser participates in activities that facilitate transactions or movement of client assets. Advice alone does not generally trigger AML/CTF obligations. Implementation and transaction involvement do.
For AFSL holders, the practical impact is significant. Businesses that provide designated services must establish and maintain an AML/CTF program, conduct customer due diligence (CDD), identify beneficial owners where required, assess money laundering and terrorism financing risks, train staff, maintain records, and report suspicious matters to AUSTRAC. AUSTRAC’s focus has increasingly shifted toward operational effectiveness rather than simply having documented policies.
Applies when:
An adviser arranges, deals in, implements, or otherwise facilitates designated financial services.
Not required when:
The business provides only strategic advice and does not participate in designated services that trigger AML/CTF obligations.
Regulatory attention is increasing in areas such as suspicious matter reporting, customer due diligence, governance, training, and risk assessments. AUSTRAC has specifically identified low suspicious matter reporting within wealth management as a supervisory concern.
Why it matters
AML/CTF failures expose AFSL holders to regulatory intervention, enforcement action, remediation costs, and reputational damage. AUSTRAC increasingly expects firms to demonstrate that AML controls operate effectively in practice through evidence, monitoring, reporting, and governance rather than relying on policies alone.
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Practical guidance
- Map every service provided by advisers and authorised representatives to determine whether any designated services are being provided.
- Review onboarding processes to ensure customer due diligence and risk assessment requirements are embedded into workflows.
- Test suspicious matter escalation, reporting, training, and governance controls before AUSTRAC supervision identifies deficiencies.
Further reading
What’s changing in 2026 under the AML/CTF reforms?