AUSTRAC’s 2026 AML/CTF Changes: Why Forward-Thinking Firms Are Already There

From 31 March 2026, AUSTRAC will lift expectations for how regulated businesses implement their Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) obligations.

For some Australian financial advice firms, this will feel like a significant regulatory change.

For others, it will feel like an overdue recalibration.

In reality, AUSTRAC is not introducing a new way of thinking — it is signalling that Australia’s AML/CTF regime is entering its mature phase.

From compliance artefacts to governance intelligence

What AUSTRAC is now demanding is not more documentation, but better intelligence.

The era of static AML programs, legacy risk acceptance and “tick-the-box” reviews is closing. In its place is a clear expectation that firms can:

• Identify and understand their real money-laundering and terrorism-financing risk

• Demonstrate that controls are proportionate and effective

• Adapt continuously as risks, products, clients and legislation evolve

This is a shift from compliance artefacts to living governance systems.

A model built for the future — not the regulator

When I designed and implemented AML/CTF frameworks for financial advice organisations in the UK, the objective was never to meet minimum regulatory requirements.

The objective was to eradicate legacy risk, anticipate emerging threats, and ensure the business could adapt before regulation forced the issue.

That philosophy led to the development of an all-encompassing, firm-wide RAG-rated risk assessment, covering every facet of the organisation — not as an annual compliance ritual, but as a continuous improvement system.

The gold-standard approach: continuous risk visibility

At its core, this model treated AML/CTF as a board-level governance capability rather than a technical compliance function.

Key features included:

1. A comprehensive firm-wide risk assessment

A structured assessment spanning:

• AML and CTF exposure

• Client types and behaviours

• Products and services

• Delivery channels

• Geographic exposure

• Third-party and outsourcing arrangements

• Technology, data integrity and operational dependencies

Risks were assessed on both an inherent and residual basis, graded using a Red / Amber / Green framework, and supported by clear evidence.

2. Board-ready risk intelligence

The output was not a policy document — it was decision-useful insight.

Boards received:

• Clear visibility of where risk genuinely sat

• Confidence in what was well controlled

• Early warning signals where weaknesses were emerging

• A prioritised remediation roadmap

This enabled proactive intervention, not reactive response.

3. Embedded remediation and accountability

Identified risks were not filed away — they were owned.

Each issue had:

• A defined remediation action

• An accountable owner

• A timeframe for completion

• Validation that controls were operating as intended

This closed the loop between risk identification and risk reduction.

4. Continuous adaptation, not periodic review

Critically, the framework was designed to evolve.

Changes in:

• legislation

• client behaviour

• technology

• delivery models

• geopolitical risk

automatically triggered reassessment. The system was alive — not refreshed once a year and forgotten.

Why this matters for Australia now

AUSTRAC’s 2026 changes are not about raising the ceiling.

They are about raising the floor.

Organisations that continue to treat AML/CTF as a static compliance obligation will struggle — even if their documentation appears adequate.

Firms that treat AML/CTF as a dynamic governance discipline will find themselves well ahead of regulatory scrutiny.

The real opportunity

Handled properly, this is not a regulatory burden. It is an opportunity to:

• Eliminate legacy risk

• Strengthen governance and board confidence

• Improve risk-based decision-making

• Build organisational resilience

• Future-proof the licence

This is where compliance evolves into a strategic advantage.

Final thought

Regulation rarely rewards those who wait.

It consistently validates those who lead.

AUSTRAC’s direction of travel is now clear. The question for advice firms is not whether they can meet the new expectations — but whether they are willing to rethink AML/CTF as a living system of governance, not a regulatory afterthought.

About the author

Tony Beaven is an award-winning executive and governance specialist with deep experience designing and implementing forward-looking AML/CTF, risk and compliance frameworks across Australia and the United Kingdom.

AUSTRAC is raising the bar in 2026.

Minimum compliance’ will no longer protect advice firms.