AML/CTF Reform: What existing reporting entities need to know before 31 March 2026
Australia’s AML/CTF reforms represent one of the most significant shifts in the country’s financial crime regulatory framework in recent years.
Designed to address the evolving risks of money laundering, terrorism financing, and proliferation financing, these changes will fundamentally reshape how organisations identify, manage and mitigate financial crime risk.
For existing reporting entities, the 31 March 2026 is the date when new obligations formally commence for existing reporting entities.
Author: Alexandra Hoskins, Principal
What has changed under the new AML/CTF regime?
The reformed regime is designed to be more flexible and outcomes-focused, better aligned with today’s financial and technological environment. It introduces material changes to AML/CTF program requirements, customer due diligence obligations and reporting standards, while extending the regime to new industries from July 2026.
For current reporting entities, this means reassessing how risk is understood and managed across the business. The focus is on demonstrating effective, risk-based decision-making, not simply satisfying a compliance checklist.
There are also structural changes to navigate, such as “designated business groups” replaced by “reporting groups”, requiring organisations to reconsider how compliance is coordinated at a group level.
Why does the 31 March 2026 deadline matter?
31 March 2026 is the point at which new AML/CTF obligations take legal effect for existing reporting entities. This is the commencement date, not a transitional milestone.
From this date:
Updated AML/CTF program requirements apply
Ongoing customer due diligence obligations must be in place
Governance structures, roles and responsibilities must reflect the updated framework
Some elements, including initial customer due diligence, carry transitional flexibility through to 2029. However, core obligations commence immediately and require organisations to be ready from 31 March.
AUSTRAC expects organisations to be positioned for compliance from this date. Where full implementation is still underway, businesses must be able to demonstrate a clear, documented plan and meaningful progress. That is the baseline AUSTRAC will assess against.AUSTRAC expects organisations to be positioned for compliance from this date. Where full implementation is still underway, businesses must be able to demonstrate a clear, documented plan and meaningful progress. That is the baseline AUSTRAC will assess against.
What do the AML/CTF reforms require businesses to do?
These reforms call for more than policy updates. They require a substantive uplift in how AML/CTF compliance is embedded and evidenced across your organisation.
Key focus areas include:
Reviewing and updating your AML/CTF program
Reassessing ML/TF risk frameworks
Aligning governance and accountability structures
Enhancing customer due diligence processes
Preparing for new reporting expectations
The real challenge lies in operationalising the rules in a way that withstands regulatory scrutiny, not simply understanding what has changed.
The 2026 reforms will bring substantial changes to AML/CTF compliance obligations across the gambling sector. Operators should use the time available to review existing programs and governance arrangements, and to ensure their approach is aligned with the new legislative and regulatory framework ahead of 31 March 2026.
Key takeaways
31 March 2026 is the commencement date for new AML/CTF obligations for existing reporting entities
The reforms introduce a more flexible, risk-based compliance framework
Immediate readiness is expected, even where some transitional arrangements apply
Businesses must uplift programs, governance and risk management frameworks
Senet can support you in navigating the transition and building sustainable compliance
How Senet can help
Regulatory change of this scale places real pressure on organisations already managing competing priorities. Navigating the detail, assessing the gaps, and implementing the right structures takes time and expertise that many teams are working hard to find.
We work alongside clients to translate these requirements into practical outcomes - whether that means uplifting an AML/CTF program, strengthening risk assessments, aligning governance structures, or preparing teams for what’s ahead.
About Senet
Senet is a multidisciplinary Australian firm specialising in gambling and gaming law, regulatory compliance, and business advisory services. We are the largest specialist team in Australia and based in Victoria. Recognised globally as experts in our field, we understand Australia’s complex gaming legal and regulatory landscape, enabling us to guide clients through their compliance requirements across each state and territory. Our clients range from start-ups to publicly listed global operators, both nationally and internationally. Our team is deeply immersed in the industry, often sharing insights at public speaking events, and our principals have held executive roles in a global ASX-listed entity and a 'Big Four' advisory firm, giving us a unique perspective on the challenges our clients face.
If you have any questions or would like to discuss the topics covered in this article, please contact the team at Senet.
