Proposed 2026 amendments to the AML/CTF Act
Submission Date: 27 January 2026
Preliminary comments
Commencement
As previously communicated, the Law Council has serious concerns regarding the ability of Tranche 2 reporting entities to comply with the new legislative Regime by 1 July 2026. The Law Council reiterates that the commencement of the legislation, at least insofar as it applies to the reporting entity population of legal practitioners, should be delayed until 1 July 2027. If this cannot be done, the Law Council recommends that consideration be given to delaying commencement of, and/or temporarily modifying the application of, the specific aspects of the AML/CTF Act detailed in Annexure A.
Alternatively, AUSTRAC should implement a transitional compliance period of at least 24 months following July 2026, during which AUSTRAC will focus on education and assistance for Tranche 2 entities in complying with their new obligations, rather than pursuing compliance through enforcement.
Other recommended amendments
The Law Council recommends that consideration be given to making other important amendments to the AML/CTF Act, including clarifying in the legislation the meaning of the word ‘customer’ and the scope of application of the professional services designated services, located in Table 6, Section 6.
Last Updated on 22/04/2026
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