FINANCIAL SERVICES · REFORMED OBLIGATIONS
AML/CTF compliance for Australian financial services firms
Financial services sits across both sides of the reform. Some of what you do may have been regulated for years; some of it became a designated service only recently. Knowing which is which is the whole job.
Already regulated? The regime still changed.
The reforms did not just add new sectors. From 31 March 2026 the program structure, customer due diligence framework and governance obligations changed for every existing reporting entity, and independent reviews of Part A became independent evaluations of the whole program. A program that was compliant in February needed rebuilding, not refreshing.
- 31 March 2026Reformed obligations begin for existing reporting entities
- 1 July 2026Full professional services obligations for transitioning advisers
- 29 July 2026Enrolment deadline for newly regulated businesses
- 31 March 2029End of the transitional period for initial CDD
Are you captured?
This sector is the most layered of the five. Advisers holding an AFSL who previously provided only arranging services had a transitional path through to 1 July 2026, after which the full professional services obligations apply. Other financial services have been captured for years and had their obligations changed on 31 March 2026.
Likely captured
- Arranging for a person to receive a designated service
- Managing client money, accounts or securities
- Forming or managing companies, trusts or other legal arrangements for clients
- Acting as, or arranging, a nominee director, shareholder or trustee
- Assisting a client to plan or execute a business or share transaction
- Lending, deposit-taking and other traditional table 1 services, where you provide them
Generally outside scope
- General financial literacy content and education
- Referrals with no arranging element
- Services provided entirely outside Australia with no Australian nexus
Capture depends on the designated services you provide — not on your profession, your licence or your job title.
What you need in place
Enrol and register with AUSTRAC
Every reporting entity has to be on the register. Enrolment is the entry point for everything else, including how your evaluation timing is set.
Appoint an AML/CTF compliance officer
A named person with the authority, seniority and time to run the program — and AUSTRAC has to be notified of the appointment.
Write an ML/TF risk assessment
Covering your customers, the designated services you provide, your delivery channels and the jurisdictions you deal with, with the reasoning visible.
Document your AML/CTF policies
Policies, procedures, systems and controls that follow from the risk assessment, approved by a senior manager rather than filed unread.
Run initial customer due diligence
Identify and verify your customer before you provide the designated service, at a depth that matches the risk you have assessed.
Screen for sanctions, PEPs and adverse media
Screening at onboarding and again over the life of the relationship, with the result recorded either way.
Trace beneficial ownership
Where the customer is a company, trust or other arrangement, identify who ultimately owns or controls it — and show how you got there.
Keep ongoing customer due diligence running
Monitoring is not an onboarding task. Relationships have to be reviewed and re-screened as risk and circumstances change.
Report suspicious matters
Submit suspicious matter reports within the required timeframes, plus threshold transaction reports where they apply to you.
Keep records
Generally seven years, with the retention clock starting at different points depending on the record type.
Train your people
Risk-appropriate AML/CTF training for staff, refreshed over time and delivered to new starters as they join.
Have the program independently evaluated
An independent evaluation of the whole program on the cycle your policies set, with findings tracked to closure.
Establish whether you were already a reporting entity
Your transitional path and deadlines differ depending on whether you were regulated before the reforms. Settle this first, because it drives everything else.
Document your ACIP transition
If you relied on applicable customer identification procedures, record which customer classes transition to the new initial CDD framework and when each one stops.
See the evidence, not just the promise.
How True Comply helps
Map which service lines are captured
And under which limb, so the program is scoped correctly rather than defensively.
Verification for retail and complex clients
Screening and verification that works for individuals and for layered entity structures.
Ownership tracing across layers
Beneficial ownership traced through layered corporate and trust ownership chains.
Ongoing monitoring across the book
Your whole client book stays monitored for $1 per person per month.
Program design for mixed obligations
Built for a firm carrying both legacy and newly captured obligations at once.
A named advisor
For the scoping and transitional judgement calls that don't have a clean answer.
Free to start. $1 per person per month for ongoing monitoring.
Start with your first checks at no cost, then keep your whole client book monitored for a dollar a person a month.
Questions, answered.
Related insights
- Getting compliant
Your AML/CTF obligations, in plain English
6 min read
- Scope
‘Are we even captured?’ How AML/CTF scope really works
4 min read
- Assurance
Your first independent evaluation: what AUSTRAC actually expects
6 min read
- Getting compliant
Have you already hit 'set and forget' on your AML program?
5 min read
Compliance you can prove.
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