On 30 September 2026, AUSTRAC began issuing infringement notices to tranche 2 entities in the real estate, accounting and jewellery sectors that AUSTRAC believes have failed to enrol. A failure to enrol with AUSTRAC is a breach of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).
The infringement notices include a fine of $21,840 for companies and $4,368 for individuals, but can accrue on a daily basis (i.e. a reporting entity technically commits a separate contravention each day that it is not enrolled on or after its enrolment deadline). Relevantly, this is more than what it would generally cost these businesses to have their designated services assessed and a comprehensive AML/CTF Program prepared for them.
Key Takeaway
If you operate in the real estate, accounting or jewellery sector (or the legal sector, which is now also regulated under the AML/CTF Act) and you have not yet assessed whether or not you are providing one or more designated services that mean you need to enrol with AUSTRAC, you should do so as soon as possible.
As provided by AUSTRAC CEO Brendan Thomas:
“The small number [of businesses] that continue to ignore their obligations should not expect AUSTRAC to ignore them.”
“We are actively looking for businesses that haven’t enrolled and we will issue more infringement notices where necessary, so if you have obligations under the scheme, now is the time to come forward… and get enrolled.”
“Enrolment is a simple first step, and there is no excuse for failing to take it.”
If you are unsure whether or not you are providing one or more designated services, or would like assistance with complying with your AML/CTF obligations, please get in touch with Cowell Clarke’s Financial Services & AML/CTF Team at Compliance@CowellClarke.com.au.
You can read AUSTRAC’s full media release here.
Our team would like to thank Sacha Mutze for her assistance with 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.