The 2026 reforms
Australia’s AML/CTF regime has changed
The biggest overhaul of Australia’s anti-money laundering laws since 2006 is now in force. For existing reporting entities, the reformed AML/CTF program and customer due diligence obligations took effect on 31 March 2026. The old Part A and Part B program structure is gone, replaced by a single program built on your own money laundering, terrorism financing and proliferation financing risk assessment.
From 1 July 2026, the regime also covers businesses that provide certain services for the first time, including lawyers, conveyancers, real estate agents, accountants, trust and company service providers, and dealers in precious metals and stones. Newly regulated businesses had to enrol with AUSTRAC by 29 July 2026 if they were already providing those services, or otherwise within 28 days of starting.
We help both groups: established reporting entities updating their programs, and businesses building an AML/CTF framework for the first time. See AUSTRAC’s summary of the changes for more.
Who we help
Advice for regulated businesses of every size
Banks and non-bank lenders
Program uplift, risk assessments and customer due diligence for lenders, credit providers and mortgage businesses.
Fintechs and payment providers
Working out whether the AML/CTF Act applies to your product, and building a program that scales as you grow.
Newly regulated professionals
Law firms, conveyancers, accountants and real estate businesses brought into the regime from 1 July 2026.
Boards and senior managers
Clear advice on governance, oversight and what the reformed regime expects of senior management.
How we help
Our AML/CTF services
- ML/TF and proliferation financing risk assessments tailored to your business
- Drafting and updating AML/CTF programs and policies under the new Rules
- Customer due diligence procedures, including beneficial ownership, politically exposed persons and sanctions screening
- AUSTRAC enrolment and registration
- Governance: compliance officer appointment, senior manager approval and board oversight
- Independent evaluations, reviews and on-site or remote audits of your program
- Suspicious matter, threshold transaction and international funds transfer reporting
- Tipping-off, reliance arrangements and dealing with high-risk customers
- Responding to AUSTRAC inquiries, breaches and applications for exemptions or modifications
Why Hindsight
Why clients choose us
We’ve sat on the bank’s side
Our partners worked at Dentons, Macquarie Bank and NAB, so we know how AML/CTF programs actually run inside a financial institution.
Practical, proportionate programs
We build frameworks that fit your size and risk, not a big-bank template your team can’t run.
Partner-supervised, every matter
Every matter is supervised by one of our Founding Partners, from first advice to final sign-off.
Clear scope and fees
We agree the scope and fees with you upfront, so there are no surprises.
Our partners
The team behind your program
Our AML/CTF work is led by our Founding Partners, who have advised some of Australia’s largest financial institutions on AML/CTF, privacy and financial services regulation.
Michael Lazar
Founding Partner
Formerly NAB and Dentons. Advises banks, credit providers and SMSF lenders on regulation and structuring.
AJ Sridaran
Founding Partner
Formerly Macquarie Bank and Dentons. Legal 500 ‘lawyer to note’ in fintech and financial services regulation.
Experience includes drafting AML/CTF programs and advising a number of financial institutions on AML/CTF risk
Meet our partners →FAQs
Frequently asked questions
Is my business now regulated under the AML/CTF Act?
It depends on the services you provide, not just your industry. From 1 July 2026, lawyers, conveyancers, real estate agents, accountants, trust and company service providers, and dealers in precious metals and stones are covered when they provide certain designated services, such as helping clients buy or sell real estate or set up companies and trusts. We can assess whether your services are caught.
What does an AML/CTF program need to include now?
A program must be based on your money laundering, terrorism financing and proliferation financing risk assessment, and include AML/CTF policies that suit your business’s nature, size and complexity. It must be approved by senior management and overseen by your governing body, and you must appoint an AML/CTF compliance officer.
We already have a Part A and Part B program. Do we need to change it?
Yes. Since 31 March 2026, the Part A and Part B structure no longer applies. Existing programs need to be updated to meet the reformed requirements, including a documented risk assessment and updated customer due diligence procedures.
How often does our program need an independent evaluation?
AUSTRAC’s guidance is that an independent evaluation is required in certain circumstances and at least once every three years. We can carry out the evaluation or help you prepare for one.
Can you help if AUSTRAC contacts us?
Yes. We advise on AUSTRAC inquiries, compliance assessments and breaches, and help you respond clearly and promptly.
Talk to us
Need help with your AML/CTF obligations?
Whether you’re updating an existing program or building one for the first time, book a call and we’ll tell you what you need to do and what it will cost.