AML Mate / Journal

Compliance articles

Browse compliance articles, practical guides and commentary for Australian professionals.

37 articles Page 1 of 4

Latest reading Compliance

Not a Company, Not a Trust: CDD on a Partnership, Club or Association Under Tranche 2

The two-partner practice, the farming family partnership, the tennis club selling its clubhouse. These clients fall outside the company and trust templates, and AUSTRAC has a CDD guide written for exactly them. Here is who you identify, what verifies what, why 20% can mean you skip someone, and the strata carve-out most firms have not noticed.

22 Oct 2026 11 min read

Read the article

More from the journal

1 to 12 of 37

Compliance13 Oct 202611 min read

You Do Not Need Transaction Monitoring Software. You Need Thirty Minutes a Month and a Record That You Spent Them.

Ongoing customer due diligence is the part of the regime that never finishes, and three months in it is the part most small firms have not started. AUSTRAC says monitoring can be manual, automated or both, and spells out what a manual routine looks like. Here is that routine for a small Tranche 2 firm: what to look for, when a client's risk rating and KYC information must be reviewed, and what to write down.

Compliance9 Oct 202611 min read

High Risk Is a Rating, Not a Verdict. AUSTRAC's Note to the Banks Is Also a Manual for Your Riskiest Client.

On 30 September 2026 AUSTRAC told financial institutions that a higher risk rating does not automatically mean declining or ending a relationship. The article is written for banks, but the same logic runs through the guidance every Tranche 2 firm works under. Here is what you may do with a client you have rated high, what you must do if you keep them, and how to end it cleanly, and without tipping off, if you do not.

Compliance7 Oct 202611 min read

AUSTRAC Just Told Enrolled Firms What Comes Next. The Last Item Is the One With a Clock: Reviewing Your Program.

On 30 September 2026 AUSTRAC published a short piece for firms that have enrolled, and its last heading is the one most small firms have not planned for: your program is not a one-off task. Here are the events that force a review of your risk assessment and policies, how fast each one has to happen, who signs off, and the 14 day rule for writing it down.

Compliance5 Oct 20267 min read

The Letters Were a Question. The Infringement Notices Are the Answer: AUSTRAC Starts Fining Firms That Never Enrolled.

On 30 September 2026 AUSTRAC began issuing infringement notices to real estate, accounting and jewellery businesses it believes never enrolled. The notices start at $21,840 for a company and $4,368 for an individual, and can accrue daily. Here is what the step means, who is next, and why the enrolled majority should read it too.

Compliance28 Sept 20267 min read

The AML/CTF Cheatsheet: 31 AUSTRAC Terms Every Tranche 2 Firm Hears, One Line Each

CDD, ECDD, SMR, TTR, PEP, beneficial owner, designated service. Three months into the regime, the vocabulary is still the first wall a small practice hits. Here is every term in one line each, the ten numbers worth remembering, and a link to the AUSTRAC page and our deeper guide for each. Save the image, pin it next to the front desk.

Compliance22 Sept 202612 min read

AUSTRAC Rewrote One Section of Its SMR Page on 9 September. Your Suspicious Matter Report Now Has to Show Your Enhanced CDD Homework.

On 9 September 2026 AUSTRAC added an enhanced customer due diligence section to its suspicious matter reports page. One part restates a rule that has been in force since July. One part is new: if you have already run enhanced CDD on the customer, AUSTRAC expects a summary of it, and what it showed, inside the SMR. And the report cannot wait for the file. Here is what changed, what did not, and how to write the summary without tipping anyone off.

Compliance18 Sept 202615 min read

The Person Giving You Instructions Is Not Your Customer. AUSTRAC Wants Both Identified, and the Paper Between Them.

The office manager who emails on behalf of the company. The son selling his mother's unit under a power of attorney. The buyer's agent bidding for a couple at auction. In each case the person you deal with is not the customer, and AUSTRAC's initial CDD lists them as a separate matter: identify the representative, establish their authority to act, and screen them. Here is who counts, what evidence of authority looks like, when you can skip verification, and what has to be in the file.

Compliance11 Sept 202613 min read

The Client Wants to Start Today and the Checks Are Not Finished. AUSTRAC Allows That, on Two Conditions and a 20 Day Clock.

Initial CDD comes before the service. There is a narrow exception, and ten weeks into the regime it is the one firms reach for without having read it. You may start before verification is finished, but only if delay is essential to avoid interrupting the ordinary course of business and the added ML/TF risk is low. Here is what you can actually delay, what never moves, and the 20 business day clock that starts the moment you act.

Compliance8 Sept 202613 min read

Another Firm Already Verified Your Client. AUSTRAC Lets You Rely on That in Two Ways, and Both Come With Paperwork.

Ten weeks into the regime, the CDD question that keeps coming up is not how to verify a client. It is whether you have to, when another firm in the same transaction already did. AUSTRAC's answer is yes, in two forms: a case-by-case file note, or a written arrangement a senior manager approves and you reassess at least every two years. Here are the conditions, what the referring firm has to hand over, and why an ID-check vendor never counts.

Compliance7 Sept 202611 min read

Enhanced CDD Is Not a Risk Rating. AUSTRAC Lists Six Triggers, and Five Fire After Onboarding.

Most firms treat enhanced customer due diligence as a label attached to a high risk client on the day the file is opened. AUSTRAC's guidance lists six circumstances that require it, and only one of them is the risk rating. The other five can fire months into a matter, on a client you marked low. Here is each trigger, what the measures actually have to do, and what has to end up in the file.

Compliance4 Sept 202611 min read

AUSTRAC Is Investigating Western Union. The Test It Named Is 'Known Patterns', and It Has Already Published Yours.

On 1 September 2026 AUSTRAC opened an enforcement investigation into Western Union and, unusually, published both the file behind the decision and the three tests it will run: does the program work, does monitoring catch known patterns, and who really makes the decisions. Here is each test at the scale of a four-person practice, and why the sequence that led here matters more than the name on the release.