Free PDF
The Tranche 2 enforcement casebook
12 Australian cases and 10 from UK and New Zealand law, accounting and estate agency firms: enrolment fines, a missed compliance report that ended in the Federal Court, late suspicious matter reports, audits regulators ordered and firms paid for. For each one, what went wrong and what to have in place at your firm. Every case names its source.
- 22 cases, each with its source
- What to have in place for each one
- A 15 point self-check, 26 pages
- No signup or trial needed
Inside the casebook
A summary of each Australian case. The PDF adds what to have in place for each one, 10 cases from UK and New Zealand professional firms, regulator statistics and a 15 point self-check. Facts checked against the sources below on 6 October 2026.
1. Enrolment
AUSTRAC starts fining firms that never enrolled
30 September 2026
AUSTRAC began issuing infringement notices to real estate, accounting and jewellery businesses it believes did not enrol within 28 days of providing a designated service: $21,840 for a company and $4,368 for an individual, which AUSTRAC says can accrue daily.
An allegation, not a finding.
2. Annual compliance report
The notice was the cheap way out
September 2024 to May 2026
Castra Licensee and Princeton Securities did not lodge their 2023 compliance report and did not pay the infringement notices that followed. The Federal Court ordered $50,000 plus $15,000 costs and $45,000 plus $5,000 costs. In 2024 AUSTRAC issued 24 notices for missed reports, from $3,300 for sole traders.
Decided by the Federal Court.
3. Your AML/CTF program
You can outsource the program, not the obligation
July 2025, proceedings ongoing
AUSTRAC alleges Mounties had not adopted and maintained a compliant program, with aspects outsourced to a third party provider. AUSTRAC said what a business "can’t outsource is its AML/CTF obligations."
An allegation, not a finding.
4. Risk assessment
When every client is low risk, AUSTRAC looks closer
May 2025
AUSTRAC ordered an external audit of Mercedes-Benz Financial Services after concerns including assuming most customers were low risk. In that sector, 89 per cent of businesses said they had no high risk customers at all.
5. Independent evaluation
Ordered to pay for its own audit
21 May 2026
AUSTRAC ordered Bankstown District Sports Club to appoint an external auditor under section 162 of the AML/CTF Act. AUSTRAC set the scope, and the club pays for the audit.
6. Source of funds
The bank approved the loan. The income was fake.
19 August 2026
Operation Claw analysed data from 10 major banks and found potentially hundreds of millions of dollars in suspected fraudulent loans, mostly linked to Sydney properties. A recurring warning sign was the repeated use of mortgage brokers, accountants and law firms across multiple loan applications.
7. Beneficial ownership
The director on the register was not the one in control
Charged November 2025
An AFP and NSW Police operation dismantled a syndicate accused of laundering more than $150 million linked to illicit tobacco. It allegedly recruited "straw directors" to register businesses and open bank accounts, then took the accounts over.
An allegation, not a finding.
Source: AFP media release
8. Suspicious matter reports
Four reports, each one late
Early 2025
AUSTRAC alleged that Cointree, a digital currency exchange, did not give suspicious matter reports within 3 business days of forming the suspicion on four occasions: $18,780 each, $75,120 in total.
An allegation, not a finding.
9. Reporting deadlines
Reporting it yourself did not avoid the fine
August to September 2025
Revolut told AUSTRAC it had submitted international funds transfer reports late. AUSTRAC still issued an infringement notice for 10 alleged contraventions, $187,800 in total, which Revolut paid in full.
An allegation, not a finding.
10. Reporting routine
The fix worked. The routine did not.
October 2025 to August 2026
Cryptolink met the conditions of its enforceable undertaking, then failed to lodge threshold transaction reports and did not answer AUSTRAC. Its registration was suspended for three months and its 96 crypto ATMs went offline.
11. Dealers in precious metals
It shouldn’t take AUSTRAC intervention
November 2023 to July 2025
After an external audit, Gold Corporation (Perth Mint) gave an enforceable undertaking over failings in ongoing customer due diligence, reporting suspicious matters and keeping enrolment details current. AUSTRAC released it in July 2025.
Source: AUSTRAC article, 22 July 2025
12. Remediation
Two years to fix five areas
May 2024 to July 2026
Sportsbet gave an enforceable undertaking to uplift five areas of its AML/CTF program. AUSTRAC closed it in July 2026 after an external auditor confirmed the work, saying completion "does not lessen our expectations."
General information, not legal advice. Proceedings, charges and infringement notices are allegations unless a court has decided them. AML Mate is not affiliated with or endorsed by AUSTRAC.