AUSTRAC has released principles-based guidance to help newly regulated tranche 2 sectors understand whether they are captured and how to meet AML/CTF obligations. This includes guidance on designated services, enrolment, AML/CTF programs, and customer due diligence, with a focus on scalable, risk-based implementation rather than prescriptive rules.
Expanded Answer
AUSTRAC’s guidance for newly regulated sectors focuses first on scope. It helps businesses determine whether they provide a designated service and whether there is a sufficient geographical link to Australia. This reflects AUSTRAC’s long-standing position that the regime applies to services, not professions, and that entities must assess their own activities carefully before assuming they are captured.
The guidance then outlines core obligations. These include enrolling with AUSTRAC, developing and maintaining an AML/CTF program, conducting customer due diligence, and implementing ongoing monitoring and reporting processes. AUSTRAC emphasises a risk-based approach, meaning firms are expected to tailor controls to their size, complexity and exposure to financial crime risk rather than apply uniform checklists.
In practice, AUSTRAC is signalling that newly regulated sectors will be judged on how well they understand and apply risk, not just whether documents exist. This increases scrutiny where businesses adopt generic templates, fail to assess customer risk properly, or treat AML/CTF as a compliance formality. For advisers working with these sectors, this also raises due diligence expectations on counterparties. See AML/CTF financial planners Australia and Five AML questions you must be able to answer.
Why it matters
AUSTRAC’s guidance sets expectations early for sectors new to regulation. Firms that misunderstand scope or apply generic AML programs are more likely to face onboarding delays, weak controls and regulatory attention once enforcement activity increases after 2026.
Practical guidance
- Assess whether your services meet AUSTRAC’s designated service definitions before assuming you are in or out of scope.
- Build an AML/CTF program that reflects your actual client base, products and delivery channels.
- Train staff to explain customer risk, monitoring and reporting decisions, not just follow procedures.
Further reading