On Wednesday, 25 March 2026, AUSTRAC made a number of changes to the Anti-Money Laundering and Counter-Terrorism Financing Rules 2025 (“AML/CTF Rules”).
These changes aim to improve how the AML/CTF Rules operate and address issues identified since their completion on 29 August 2025.
Reporting Groups
The changes introduce an ‘opt-out’ reporting group model. This means related entities within a corporate group or other control structure will form a reporting group by default, unless a reporting entity declines membership in writing.
Changes have also been made to the lead entity provisions to support this model.
The new approach is intended to reduce the administrative burden of forming a reporting group while keeping the process for opting out relatively simple.
Initial Customer Due Diligence
The changes also amend the customer due diligence provisions, particularly in relation to identifying beneficial owners.
In broad terms, the streamlined approach applies where the customer is a government body or is controlled by a listed public company or government body. It also covers some partly owned entities, where an individual is only treated as a beneficial owner due to that ownership relationship.
Overall, these changes are aimed at reducing unnecessary compliance steps where ownership or control is sufficiently transparent due to the nature of the customer.
Compliance Reports
Annual compliance reports will now be lodged by reference to the financial year, rather than the calendar year. They will be due within three months after the end of the financial year, being 30 September each year.
Importantly, the first annual compliance report will be due on 30 September 2027 for the 2026/27 financial year. To facilitate this transition, no compliance report is required to be submitted for the period between 1 January 2026 to 30 June 2026.
Next Steps
These amendments will likely require reporting entities to update any AML/CTF Program that they have already adopted. Reporting entities should review their AML/CTF programs, reporting group arrangements and initial CDD processes to make sure they reflect the updated Rules.
If you would like advice on how these changes affect your business, please contact the writers or Cowell Clarke’s AML/CTF team at Compliance@CowellClarke.com.au.
We’d like to thank Ivanna Tan, Law Clerk, for her contribution to this insight.
This publication has been prepared for general guidance on matters of interest only and does not constitute professional legal advice. You should not act upon the information contained in this publication without obtaining specific professional legal advice. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication and to the extent permitted by law, Cowell Clarke does not accept or assume any liability, responsibility or duty of care for any consequences of you or anyone else acting or refraining to act in relation on the information contained in this publication or for any decision based on it.