AUSTRAC has started issuing infringement notices to unenrolled businesses

On 30 September 2026, AUSTRAC announced that it has begun issuing infringement notices to businesses it believes were required to enrol under the reformed AML/CTF regime and had not. The sectors named were real estate, accounting and jewellery — three of the industries that came into scope on 1 July 2026.

This is the follow-through we wrote about in August. The warnings were always going to be followed by something with a figure attached to it, and that has now happened. Here is what has actually been announced, what an infringement notice is and is not, and what to do if your business could be in the same position.

What AUSTRAC has announced

The essentials, as AUSTRAC has stated them. AUSTRAC says it believes the recipients failed to enrol within 28 days of providing a designated service. The infringement notice amounts are $21,840 for a corporate entity and $4,368 for an individual — and AUSTRAC says those amounts can accrue daily while the failure continues.

• The sectors named in the announcement were real estate, accounting and jewellery
• AUSTRAC did not identify the recipients, and it has not disclosed how many notices were issued
• The stated trigger is failure to enrol within 28 days of providing a designated service
• AUSTRAC has published the amounts as $21,840 for a corporate entity and $4,368 for an individual, which it says can accrue daily

The announcement is AUSTRAC's to make in its own words — you can read AUSTRAC's media release in full. Everything below works from what it says, and from what it does not.

What an infringement notice is — and is not

It helps to be precise, because the announcement will be read emotionally by some and defensively by others. An infringement notice is an enforcement response to an alleged enrolment failure. That is its scope.

It is not proof of money laundering, and no allegation of money laundering sits behind it. It is also not, by itself, a finding that a business's broader AML/CTF program has failed. A notice issued for an alleged enrolment failure says nothing about whether a firm's risk assessment, due diligence or monitoring would have stood up — those are separate obligations, assessed separately.

The corollary matters just as much: resolving a notice does not close out the regime. A business that pays a penalty for late enrolment is still a reporting entity, still needs a compliant program, and is still exposed on everything it has not yet built.

Scope follows services, not job titles

The notices went to real estate, accounting and jewellery businesses, which is why headlines will name professions. But the trigger was never the profession — it is whether the business provides a designated service. That distinction is doing real work in each of these sectors.

For real estate, brokering the sale, purchase or transfer of real estate is generally the relevant real-estate designated service. A business that only manages rental properties, and does not broker transactions, may sit outside the real-estate designated service depending on what it actually does — the answer follows from the services provided, not the agency sign on the door.

For accountants, capture depends on providing one or more of the professional designated services — for example, certain company or trust formation work, assisting with transactions, or managing a client's money or property. Merely holding an accounting or tax-agent title does not make a practice captured, and ordinary tax and accounting work is not automatically brought into the regime. The question is whether the work itself crosses into a designated service.

If you are not sure which side of that line your work sits on, our free 2-minute scope check gives an initial indication based on the services you select, and how scope actually works explains the reasoning behind the question.

What to do if this could be you

The order matters. Firms that try to fix everything at once usually end up with a lot of activity and little that can be shown for it. Work through it in sequence:

• Confirm whether the services you actually provide include a designated service — and write down the conclusion either way
• If you are captured and not enrolled, enrol promptly. Do not backdate anything; the enrolment date should be true
• Document the gap and what you are doing to remediate it, with dates
• Appoint your AML/CTF compliance officer and notify AUSTRAC of the appointment
• Complete your risk assessment and AML/CTF program
• Begin customer due diligence, applicable transaction and suspicious matter reporting, staff training and record keeping
• Organise your evidence as you go, so the remediation is demonstrable rather than asserted

The detailed sequence behind those steps is set out in what to do if you missed the enrolment deadline, and it has not changed — only the cost of deferring it has.

What this means for real estate agencies

Agencies broking property transactions are squarely in the group this announcement addresses. If enrolment is done but the program, screening and evidence trail are not, the notice risk has passed but the operational one has not — enrolled is not the same as operational, and the next phase of enforcement will not stay at enrolment forever.

Our real estate AML readiness page sets out what operational looks like for an agency, beyond the enrolment itself.

What this means for accounting practices

For accounting and advisory practices, the first task is the scope question: which service lines involve designated services, and which do not. A practice that is captured needs enrolment, a program and evidence, whether or not it ever expected to be. A practice that concludes it is not captured should have that conclusion written down and dated, attached to the services it actually provides.

The sector-specific obligations are covered in our accounting sector guide.

The direction of travel

In August we argued the first enforcement wave would be administratively cheap and high-volume rather than courtroom litigation, aimed at firms that simply never enrolled. That is broadly what this announcement looks like: notices for an enrolment failure, with the amounts and the accrual published, and no names attached. What it confirms is that the practical threshold has moved from warning to consequence.

The reasoning behind that read is in AUSTRAC hasn't changed its posture. It's changed phase. — a natural companion to this piece.

True Comply exists for firms that would rather be able to prove compliance than argue about it — program, screening and an evidence trail that builds as you work. If you are unsure whether you are captured, start with the scope check. If you know you are behind, the deadline article sets out the recovery order. Either way, start this week.