AML Mate / Journal

General articles

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

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AUSTRAC Found the Fraud Inside the Loan. The Bank Approval Was Never Your Source of Funds Answer.

On 19 August 2026 AUSTRAC published what Operation Claw found inside Australian mortgage books: hundreds of millions in suspected fraudulent loans. Inflated incomes, fabricated business activity, and offshore or third-party money completing settlements. AUSTRAC's own guidance offers a bank loan as the example of a source of funds that is clear without further work. That example just got a footnote, and the part of the picture nobody else can see sits in your file.

24 Aug 2026 10 min read

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1 to 12 of 59

General13 Aug 20267 min read

"We Don't Take Cash" Is a Policy, Not a Fact. The $10,000 Rule Every Tranche 2 Firm Still Has.

Every professional firm says the same sentence: we don't take cash. The Act does not care what your policy says, it cares what happened. A threshold transaction report is due within 10 business days of any $10,000-plus physical currency transaction, separate payments are counted separately, and a client who splits payments to stay under the line has just handed you a different report to file. Here is how the rule actually reaches firms that think it never will.

General12 Aug 20266 min read

AUSTRAC Just Took a Business Offline. Not for Its Old Breaches. For the Routine That Came After.

On 9 August 2026 AUSTRAC suspended Cryptolink's registration and took its 96 crypto ATMs offline. Not for the breaches it had already paid for: for the routine reports and unanswered questions that came after. The remediation project succeeded and the week-to-week routine failed. Every newly regulated Tranche 2 firm is now on the same three reporting clocks, so this one is worth reading twice.

General6 Aug 20268 min read

AUSTRAC's Free Starter Kit Has an Eligibility List. Almost Nobody Has Read It.

AUSTRAC's program starter kits are free, sector-specific and genuinely good. They also come with a list of conditions, and you have to meet every one of them. Fifteen personnel including admin is the condition most firms fail, but it is not the one that catches them out. Here is the full list for each sector, and what AUSTRAC says happens if you use the kit anyway.

General20 July 20266 min read

The AUSTRAC Enrolment Walkthrough: Get It Done Before 29 July

Nine days out from the 29 July enrolment deadline, the firms still unenrolled mostly are not refusing. They are picturing a bigger job than it is. Enrolment is one online form, roughly twenty minutes if you sit down with the right details in front of you. Here is exactly what to gather before you open the form, the step-by-step through AUSTRAC Online, the receipt-versus-confirmation trap that catches people who leave it to the last day, and the one other thing due on the same date.

General17 July 20266 min read

Do I Even Need to Enrol? The Designated-Service Test Firms Keep Getting Wrong

With days left to the 29 July AUSTRAC enrolment deadline, the question that stalls the most firms is the first one: am I actually captured? The mistake is answering it by profession. Tranche 2 captures you service by service, not job title by job title. Here is the test that actually decides it, with real examples for accountants, lawyers, real estate and dealers.

General16 July 20266 min read

The AUSTRAC Audit That Costs You Nothing: What an Examination Actually Asks For

An AUSTRAC examination is only painful if you are not ready for it. It asks for a predictable set of documents. If they live in one place and are current, an audit is an afternoon. If they are scattered, or your program was a write-once PDF, it becomes a scramble that can turn into an external audit order you pay for. Here is the list they work from.

General15 July 20265 min read

Five Tranche 2 Myths That Are About to Cost Firms the 29 July Deadline

With two weeks to the AUSTRAC enrolment deadline, five comfortable beliefs are quietly steering Australian firms into missing it: that it is too late, that a small firm is invisible, that an ID check is enough, that a software vendor covers you, and that you can wait for AUSTRAC to make contact. Here is the reality on each.

General14 July 20266 min read

AUSTRAC Just Went From 19,000 to 100,000 Regulated Businesses. Who Does It Look At First?

AUSTRAC's regulated population jumped roughly five-fold overnight. It cannot audit everyone, so it will triage by risk and by signal. Here is how that triage actually works, why 'a firm my size will never get looked at' is the wrong bet, and the cheapest move that puts you on the right side of it before 29 July.

General9 July 20269 min read

Sportsbet Just Closed Its AUSTRAC Enforceable Undertaking. The Three Failures It Had to Fix Are on Every Tranche 2 Checklist.

On 3 July 2026 AUSTRAC finalised its enforceable undertaking with Sportsbet, confirming after an independent external audit that the bookmaker had remediated the AML/CTF failings the regulator flagged in 2024. The concerns clustered in three areas: risk assessment, customer monitoring and suspicious matter reporting. Those are the same three areas every Tranche 2 firm is now expected to have working.

General5 July 20266 min read

Do You Have to Run CDD on Every Existing Client? The Pre-Commencement Customer Rules, Explained

The most common question from firms in the first week of the new AML/CTF regime: what about the clients we already act for? Two answers are circulating, re-onboard everyone and you have until 2029, and AUSTRAC's guidance supports neither. Here is what a pre-commencement customer actually is, the two triggers that end the exemption, and what you still owe on your legacy book.

General3 July 20269 min read

AML Mate vs easyAML (2026): An Honest Pricing and Feature Comparison for Tranche 2 Firms

easyAML starts at $179/month plus GST with $20 per KYC check and a 12-month term. AML Mate starts at $49/month with verifications included and no lock-in. A straight, sourced comparison of the two Tranche 2 compliance platforms: pricing, verification, screening, reporting, training, and who each one actually suits.