Key Changes to the new AML/CTF Rules for existing entities
Big changes are coming to Australia’s financial crime landscape. The AML/CTF Rules 2025 represent the most significant shift in our anti-money laundering and counter-terrorism financing regime in nearly two decades.
If your business is in the legal, accounting, real estate, or other professional services sectors, you are likely now in scope. The long-awaited "Tranche Two" expansion is here, and the clock is ticking for compliance.
With over 104 pages of complex legalese, understanding your new obligations can be daunting. That’s why the compliance team at Click Legal has done the heavy lifting for you.
We’ve translated the new AML/CTF Rules 2025 into a clear, actionable, and FREE guide for busy professionals.
The layman's guide to AML/CTF Rules 2025 - New 2025 AML Rules: A Guide for All Reporting Entities
New 2025 AML Rules: A Guide for All Reporting Entities
Major changes to Australia’s financial crime laws are now in effect. The AML/CTF Rules 2025 represent a significant overhaul, impacting every single reporting entity.
Whether you are an existing Tranche 1 entity (like a bank, fintech, remitter, or gambling service) or a newly regulated Tranche 2 entity (like a lawyer, accountant, or real estate agent), your compliance obligations have changed.
Key Changes Under the AML/CTF Rules 2025
The new regime introduces critical updates that you cannot ignore:
- A New Core Risk: Proliferation Financing (PF) is now a mandatory pillar alongside Money Laundering and Terrorism Financing.
- Expanded Scope: Tranche Two is here, bringing law firms, accounting practices, real estate agents, and dealers in precious metals under AUSTRAC's regulation.
- Strict Deadlines: The new rules commence on 31 March 2026, with different transitional periods. New Tranche 2 entities must be ready to enrol on 31 March 2026 and reporting from 1 July 2026.
- Higher Standards: Enhanced governance, stricter customer due diligence, and tougher independent review requirements are now in force.
Get Your Free, Plain-English Compliance Guide
With over 100 pages of legal text, understanding your new duties is complex. Click Legal has simplified it for you.
Our free guide breaks down the AML/CTF Rules 2025 into clear, actionable insights for all businesses, covering:
- Your specific compliance timeline
- The new outcomes-based approach
- Essential updates for your AML/CTF Program
- Sector-specific changes for real estate and virtual assets
Protect your business. Ensure compliance. Start now.
Download Your Free AML/CTF Rules 2025 Guide Here
AML/CTF Independent Reviews Just Got Stricter: What You Must Know
A critical part of your AML/CTF compliance—the independent compliance review—has been significantly strengthened under the new AML/CTF Rules 2025. For all reporting entities, from banks and fintechs to law firms and accountants, the bar for testing your program's effectiveness is now much higher.
Failing to meet these new standards leaves your business exposed to regulatory action and financial crime risk.
What’s Changed for Independent Reviews?
Gone are the days of a simple tick-box exercise. The new rules mandate a more robust, evidence-based evaluation process. Here’s what the AML/CTF Rules 2025 now require:
- Test Both Design AND Effectiveness: Your reviewer must now go beyond checking if policies exist. They must rigorously test whether your AML/CTF program is operationally effective in practice at identifying, assessing, managing, and mitigating ML/TF/PF risks.
- A Direct Line to the Top: The final evaluation report must be provided directly to your Governing Body (e.g., Board of Directors). This ensures senior leadership can no longer claim ignorance of compliance failures and underscores their accountability.
- Focus on the Triad of Risk: The review must explicitly evaluate your program’s effectiveness against all three core objectives: Money Laundering (ML), Terrorism Financing (TF), and the new Proliferation Financing (PF) risk.
Is Your Business Prepared for a Higher-Stakes Review?
These changes mean your next independent review will be more intensive. You need to be prepared with:
- Comprehensive documentation of your ML/TF/PF risk assessment.
- Clear evidence that your controls are working in real-world scenarios.
- A governance structure that facilitates direct reporting to the board.
Navigate Your New Compliance Obligations with Confidence
Understanding the full scope of the AML/CTF Rules 2025 is the first step. Our free guide breaks down these complex changes into a clear, plain-English overview, giving you a actionable starting point for your compliance journey.
Ensure your next independent review meets the new, higher standard.
Download Our Free Guide to the AML/CTF Rules 2025
Don't risk a failed review. Let our AML Lawyers conduct a pre-assessment to ensure your AML/CTF program meets the new 2025 standards. Schedule a Confidential Consultation today.
Email: hello@clicklegal.com.au