Review of the Anti-Money Laundering and Counter-Terrorism Financing Amendment Bill 2026
Submission Date: 12 May 2026
Preliminary comments
Commencement
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 is firmly of the view that commencement of the legislation 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, certain specific aspects of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth); and/or
- the Australian Transaction Reports and Analysis Centre implement a transitional compliance period of at least 24 months following July 2026, during which it will focus on education and assistance for Tranche 2 entities in complying with their new obligations, rather than on pursuing compliance through enforcement.
Other recommended amendments
The Law Council is of the view that serious consideration needs to be given to making other important amendments to the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 (Cth) as a matter of urgency. In particular, the Law Council submits that the legislation needs to be amended to clarify the scope of application of the Professional Services in Table 6, Section 6(6B).
Last Updated on 21/05/2026
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