AML Mate / Journal

AML/CTF insights for your practice

Practical articles and guides for Australian professionals working through AML/CTF obligations.

104 articles Page 2 of 9

Article archive, page 2

13 to 24 of 104
Compliance11 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.

Compliance11 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.

Compliance10 min read

Your Client Exists. Their ID Doesn't. AUSTRAC Wrote a Playbook for Exactly This.

A real client who cannot produce a driver licence or passport is not a dead end. AUSTRAC publishes an alternative identification playbook, and it is more generous than most firms assume. Referee statements, government correspondence, expired ID and, as a last resort, self-attestation are all on the table, provided you assess the risk and write down what you did. Here is the whole toolkit, translated for a suburban practice.

Real Estate9 min read

The Customer Is Both the Seller and the Buyer: Real Estate's Least Expected CDD Rule

AUSTRAC is blunt: broker a property sale and the customer is both the seller and the buyer. You must run initial CDD on the side you do not act for. The workable part is the clock: 28 days after exchange of contracts, or 3 days before the initially agreed settlement day, whichever comes first. Here is the rule, the auction scenario AUSTRAC itself walks through, and what to do when the other side will not cooperate.

Compliance8 min read

Gold Bullion, Luxury Watches, 280,000 Vapes: AUSTRAC's Tobacco Strike Is a Tour of the Sectors It Now Regulates

AUSTRAC's illicit tobacco strike seized cash, gold bullion, luxury watches and 280,000 vapes, and restrained $25 million in property and shares. The network ran through legitimate freight businesses, and the asset list reads like a map of the sectors AUSTRAC now regulates. Here is what the operation looks like from inside a client file, and which routine obligations are built to catch it.

General10 min read

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.

Compliance8 min read

Your First AUSTRAC Compliance Report Is Not Due Until 2027. It Is Being Written Right Now.

Your first AUSTRAC compliance report covers 1 July 2026 to 30 June 2027 and is lodged between July and September 2027, not 31 March. The questions are mostly yes/no answers and counts, and nearly all of them can only be answered from records you keep during the year. Here is what the report asks, the register that answers each question, and the small monthly habit that makes next July boring.

Compliance9 min read

Two Digits of Your AUSTRAC Account Number Have Already Scheduled Your First Independent Evaluation

Every AML/CTF program must be independently evaluated at least once every 3 years, and for newly regulated firms the deadline for the first one is already fixed by the last two digits of the AUSTRAC account number. Here is how to read your date, who is allowed to run the evaluation, what the written report must cover, and why the paperwork about it is due years before the evaluation itself.