AUSTRAC’s Reminder: Timely AML Reporting Isn’t Optional
Earlier this week, Accounting Times reported that AUSTRAC issued Revolut a $187,800 infringement notice for late reporting of international money transfer instructions. The penalty was imposed even though Revolut voluntarily disclosed the issue and took corrective action.
AUSTRAC’s message is clear: late reporting equals non-compliance. Timely submission is vital because delays weaken the regime’s ability to detect and disrupt financial crime. Cooperation after the event won’t shield you, and Revolut’s fine is small compared to the multi-million-dollar penalties AUSTRAC can impose for systemic breaches.
Why This Matters for Tranche 2 Entities, Only 10 Months to Go
Accountants, lawyers, real estate agents, and other “gatekeeper” professions will fall under the expanded AML/CTF regime from 1 July 2026, just 10 months away. As Accounting Times highlighted, Revolut’s penalty is a timely reminder of what Tranche 2 entities can expect: strict enforcement and no tolerance for reporting failures, whether late or not. If you haven’t started preparing, you are already behind. AUSTRAC has made it clear that there will be no soft launch or grace period.
Specific Risks for Lawyers and Accountants
- Accountants: company formations, structuring advice tax planning and handling client funds will now fall under AUSTRAC’s reporting regime.
- Lawyers: trust accounts, property conveyancing and corporate transactions are in scope. These are the areas in which AUSTRAC has identified as vulnerable to misuse.
These obligations are not optional. Failing to comply risks significant penalties, reputational damage, and regulatory intervention.
Deadlines You Cannot Miss
- 31 March 2026: AUSTRAC enrolment opens for Tranche 2 entities.
- 1 July 2026: You must be enrolled and fully compliant. Your AML/CTF program, systems and training must be in place.
Deadlines You Cannot Miss
- Risk Assessment: Identify how your services could be used for money laundering or terrorism financing.
- Appoint a Compliance Officer: AUSTRAC expects a senior person to take responsibility for compliance.
- Develop a Tailored Compliance Program: Policies and controls must be practical and specific to your firm.
- Set Up Reporting Systems: Ensure you can identify and report suspicious behaviour, large cash transactions and international transfers on time.
- Staff Training and Board Engagement: Compliance must be embedded into your firm’s culture, not left as a paper exercise.
Bottom Line
As Accounting Times notes, Revolut’s penalty demonstrates that AUSTRAC will take action, even when entities self-report and implement corrective measures.
For Tranche 2 professions, the countdown has begun. With only 10 months remaining until 1 July 2026, now is the time to establish compliance systems, test reporting processes, and prepare your team. Once the regime goes live, excuses won’t hold up, only compliance will.
How DVT Mcleods Can Help
At DVT Mcleods, we work with accounting and legal firms to design and implement compliance frameworks that withstand regulatory scrutiny. Our AML/CTF service, CoreComply, is delivered by specialists with expertise in financial crime risk, regulation and compliance. Whether you need a full program build, board training, or a readiness review ahead of Tranche 2, CoreComply gives you access to people with the right skills to help you prepare before the clock runs out.
If you’d like to discuss how these changes will impact your firm, contact us at 02 9633 3333
