Australia's AML/CTF Act establishes financial-crime controls for designated services, including payments. Reporting entities enrol, assess risk, conduct customer due diligence and operate an AML/CTF programme, with transaction and suspicious-matter reporting supported by records.
TL;DR:
- Designated services trigger risk assessment, AML/CTF programmes and customer due diligence.
- Reporting entities must retain records and make required AUSTRAC reports.
- 2026 reforms have transitions; enrolment and remittance or virtual-asset registration remain distinct.
Summary
Designated services establish the perimeter
The Anti-Money Laundering and Counter-Terrorism Financing Act is Australia’s statutory framework for financial-crime controls across designated services. It is relevant to payments where a business supplies a covered financial, remittance or other designated service with the required Australian connection. The legal test concerns the service and the entity providing it, rather than the use of a particular app or payment method. AUSTRAC administers the framework and provides sector-specific guidance on who is regulated.
Risk management and customer due diligence
Reporting entities must manage money-laundering and terrorism-financing risks through an effective AML/CTF programme and the applicable customer due-diligence arrangements. That work connects knowledge of the customer with the nature of the service and the risks of the relationship. The Act’s framework is supported by detailed Rules, so a general obligation to identify customers should not be reduced to one universal document checklist. Different service roles and circumstances can affect what information and controls are required.
Reporting, records and registration
The framework includes suspicious-matter reporting, other required transaction reports and record keeping, helping AUSTRAC connect financial activity with intelligence and supervision. Enrolment identifies reporting entities, while certain remittance and virtual-asset activities also have registration requirements. Those steps should not be conflated with a general payments or banking licence. A firm’s AML/CTF status concerns its financial-crime obligations and does not by itself establish that it may offer every financial product.
Updated obligations and transition in 2026
AUSTRAC states that updated obligations for existing reporting entities took effect on 31 March 2026. Its current guidance identifies transitional Rules and expects entities that cannot yet meet an updated requirement to document gaps, interim risk controls and an implementation plan, with sustained progress. Core responsibilities such as risk management, an effective programme and suspicious-matter reporting continue. The existence of transition periods therefore should not be described as a blanket suspension of AML/CTF compliance.
Keywords
- Australia AML
- AUSTRAC
- designated services
- customer diligence
- risk programmes
- transaction reports
- record retention
- remittance registration
- virtual assets
- 2026 reforms