Today is the day the anti money laundering reforms stop being a future problem. Enrolment with AUSTRAC for tranche 2 entities closes today, 29 July, four weeks after the underlying obligations commenced on 1 July.
Who must be enrolled by tonight
Any business providing designated services under the expanded AML/CTF Act: accountants and bookkeepers providing relevant services, lawyers and conveyancers, real estate professionals, and dealers in precious metals and stones. The enrolment window has been open since 31 March, so this deadline is the end of a four month runway, not a surprise.
If you are enrolled, keep going
Enrolment is step one of an ongoing regime. Your AML/CTF program needs to actually operate: customer due diligence on new engagements, a documented risk assessment, staff who know what a suspicious matter report is and when it applies, and a compliance officer who owns the framework. AUSTRAC has signalled its early focus is on entities engaging genuinely with the new rules versus those ignoring them.
If you missed it
Enrol immediately anyway. Failing to enrol by the deadline is a contravention that can attract civil penalties, but continuing not to enrol compounds it daily. Document why the date was missed, what you did to fix it and when. Regulators consistently treat honest late arrivals better than entities that wait to be found.
What clients will notice
More identity checks, occasionally slower onboarding, and firms asking questions about the source of funds on larger transactions. That is the system working. A professional adviser who never asks is now the red flag.
Super Nice is enrolled, our program is in place, and our clients will see nothing more dramatic than the occasional extra ID check. If you run a firm and today has caught you flat footed, do the enrolment tonight, then call us or an AML specialist tomorrow.