Modernising Australia's anti-money laundering and counter-terrorism financing regime

Closed 16 Jun 2023

Opened 20 Apr 2023

Feedback updated 2 May 2024

We asked

We held a first round of consultation on proposed reforms to modernise Australia's anti-money laundering and counter-terrorism financing (AML/CTF) regime between April and June 2023, following the release of our first consultation paper

We sought feedback from industry on proposals to streamline the AML/CTF regime and expand the regime to professional service providers. We also welcomed and considered general feedback on industry experience with the AML/CTF regime. The consultation paper asked 36 questions on a wide range of matters relating to how the AML/CTF regime functions. We sought public input through written submissions and targeted consultation with affected sectors.

You said

During 2023, we held over 40 targeted consultations with industry, including roundtables with national peak bodies of affected sectors, bilateral engagements with industry members and addresses at industry conferences.

We received 142 submissions to the consultation from stakeholders across all affected sectors, as well as from government, academics and individuals. With consent, we have published 114 of these submissions.

Key themes

There was broad support for the reforms, with submissions reflecting the diversity in affected sectors. Submissions provided beneficial insights into how the AML/CTF regime could be improved to remain fit-for-purpose and maintain pace with the emerging threat environment. Overall, stakeholders supported the proposed reforms to clarify the application of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (the Act) and remove ambiguity from the current provisions. Submissions highlighted the need for us to consider other government reforms. This includes initiatives such as: 

  • scams reform underway by the Australian Competition and Consumer Commission and how information sharing could support National Anti-Scams Centre activities,
  • use of new and evolving technologies, and how this could interact with proposed Customer Due Diligence (CDD) measures
  • payments reform and beneficial ownership initiatives.

Simplification and modernisation of the regime

Existing regulated entities supported changes to simplify CDD obligations and AML/CTF program requirements, with most highlighting this as a significant reform priority. Submissions expressed a strong interest in understanding how new technologies like biometric databases and digital identity could be adopted in CDD procedures. Submissions were broadly supportive of streamlining AML/CTF program requirements and proposals to facilitate and safeguard appropriate information sharing between relevant entities.

Regulation of tranche-two entities

Some stakeholder groups were supportive of expanding the AML/CTF regime to cover certain high‑risk services provided by some professions, including lawyers, accountants, trust and company service providers, real estate professionals and dealers in precious metals and stones (also known as tranche-two entities). Others, including some new sectors to be regulated, sought further information on their sector-specific risks and the regulatory impact of being brought into the AML/CTF regime. Many submissions from tranche-two entities indicated interest in leveraging existing processes and practices to help avoid duplication and reduce regulatory costs, including for CDD obligations.

Thank you to everyone who contributed to the consultation process and provided a submission.

We did

We carefully considered all feedback received during the first round of consultation and used this to inform a second series of consultation papers. These papers provide further detail on the proposed reforms as requested in the submissions. 

Find out more about the second round of AML/CTF consultation.

Feedback from both the first and second round of consultation will inform government consideration on reform to the AML/CTF regime.

Published responses

View submitted responses where consent has been given to publish the response.


On 20 April 2023 the Attorney-General announced public consultation on proposed reforms of Australia’s anti-money laundering and counter-terrorism financing (AML/CTF) regime.

The Australian Government is committed to protecting the integrity of the Australian financial system and improving Australia’s AML/CTF regime to ensure it is fit-for-purpose, responds to the evolving threat environment, and meets international standards set by the Financial Action Task Force (FATF), the global financial crime watchdog and standard-setter.

The Australian Institute of Criminology estimates that serious and organised crime costs the Australian community up to A$60.1 billion in 2020-21, with illicit financing at the centre of most crime types.1 It directly impacts the safety and wellbeing of Australian communities, and exploits and distorts legitimate markets and economic activity. The AML/CTF regime is a central part of Australia’s efforts to prevent criminals from enjoying the profits of their illegal activity and stopping funds from falling into the hands of terrorist organisations.

No legitimate business wants to wittingly, or unwittingly, assist the laundering of money that aids the commissioning of serious crimes including terrorism, child abuse and the illicit drug trade. The purpose of the AML/CTF regime is to assist businesses to identify these risks in the course of providing their services. In doing so, the AML/CTF regime sets out a range of measures to protect regulated entities that are at the front line in preventing serious financial crimes. These obligations build resilience against misuse by criminals within regulated sectors and require the reporting of certain transactions to government for use as financial intelligence to combat money laundering, terrorism financing and other serious financial crime. These reports are vital in understanding and stopping the flow of illicit funds into, out of and within Australia.

Part 1 of this consultation paper proposes reforms that will simplify and modernise the operation of the regime. The need to streamline obligations has long been called for by industry and was recommended by the 2016 Report on the Statutory Review of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (the 2016 Statutory Review). The 2016 Statutory Review found that the regime is overly complex and impedes the ability of regulated entities to understand and comply with their AML/CTF obligations. In particular, the scale, structure and density of the Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (No. 1) (the Rules) was considered to be a significant issue, rendering the Rules hard to follow and largely inaccessible particularly for small business. The feedback from industry indicated that there is a pressing need to simplify the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (the Act) and Rules, and streamline AML/CTF obligations.

Part 2 of this consultation paper proposes extending the AML/CTF regime to certain high-risk professions, including lawyers, accountants, trust and company service providers, real estate agents and dealers in precious metals and stones (also known as tranche-two entities). Out of more than 200 jurisdictions, Australia is now one of only 5 jurisdictions in the FATF Global Network, alongside China, Haiti, Madagascar and the United States, that do not regulate tranche-two entities.2

Why we are consulting

The AML/CTF regime represents a significant partnership between government and industry.

The Australian Government is committed to consulting with industry in the consideration of the reforms proposed in this paper. Consultation will occur throughout 2023. This paper will be the first step in the development of reforms to the Act. A second consultation paper, informed by industry submissions on this paper, will be released later this year. The department will also conduct roundtable discussions with key stakeholders. Engagement with industry will be undertaken on sectoral-specific issues as required.

The department invites public submissions on the proposals discussed in this consultation paper. While questions are included in the paper to guide consultations these are not intended to limit responses.

Submissions and feedback can be submitted here, using the ‘Have your say’ link at the bottom of this page. The closing date for submissions is 16 June 2023.

All submissions and the names of persons or organisations that make a submission will be treated as public, and may be published on the department’s website, unless you request that your submission be kept confidential, or if we consider (for any reason) that it should not be made public. Any submission provided on a confidential basis remains subject to the Freedom of Information Act 1982.

The department retains discretion about publishing and sharing submissions. Submissions provided without a confidentiality request may be published on the department’s website. We may also redact parts of published submissions if appropriate.

Please provide your response and any attachments online by following the ‘Have your say’ link at the bottom of this page. If you have challenges providing your submission online, you can email it to

1Smith R & Hickman A, Estimating the costs of serious and organised crime in Australia, 2020-2021. Statistical Report no. 38, Australian Institute of Criminology, 2022.

2Financial Action Task Force, ‘Consolidated table of assessment ratings’, Consolidated assessment ratings (Web Page, 03 April 2023).


  • Government
  • Legislation
  • Criminal law
  • National security
  • Corruption
  • Financial law