We have reviewed the latest guidance and are updating AML Guardian to help you manage these requirements more easily. 

Below is a summary of what you need to know. 

AUSTRAC Update – Key Changes 

 1. Annual Compliance Reporting 

Annual Compliance Reports will now follow the financial year reporting cycle: 

Reporting period: 1 July to 30 June 
Submission deadline: 30 September 

For most newly regulated businesses, the first reporting period will be: 

1 July 2026 – 30 June 2027 

with the report due by: 

30 September 2027 

AML Guardian will be updated to help you prepare for this throughout the year rather than waiting until the reporting deadline. 

2. AML/CTF Programs Must Be Used in Practice 

AUSTRAC is placing increased focus on businesses being able to demonstrate that their AML/CTF Program is actually being implemented. 

This means it is important to maintain evidence that your organisation is completing activities such as: 

• Customer identification and verification 
• Customer risk assessments 
• Enhanced due diligence where required 
• Staff AML/CTF training 
• Ongoing monitoring and reviews 
• Compliance Officer decisions and approvals 
• Suspicious matter assessments 
• AML/CTF Program and Business Risk Assessment reviews 

Having an AML/CTF Program document alone is not enough. Businesses should be able to demonstrate how their controls are operating in day-to-day activities. 

3. Customer Risk Should Be Considered During Onboarding 

Customer verification is only one part of Customer Due Diligence. 

When onboarding customers, businesses should also consider factors such as: 

• Customer type and ownership structure 
• Country and geographic risk 
• Products and services being provided 
• PEP, sanctions and adverse media results 
• Unusual behaviour or activity 
• Source of funds or source of wealth where appropriate 
• Other indicators that may increase ML/TF risk 

A successful identity verification does not automatically mean the customer has completed the full CDD process. 

AML Guardian will continue to separate identity verification, CDD, customer risk and onboarding approval to help businesses demonstrate this process. 

4. Real Estate Businesses – Counterparty CDD 

There have also been important updates relating to counterparty CDD for real estate transactions. 

Where delayed counterparty CDD is permitted, the timeframe has changed to generally allow completion within 28 days after exchange of contracts, while also taking into account the requirement to complete the process before settlement. 

Businesses should also keep evidence of attempts made to obtain CDD information where a counterparty is uncooperative. 

Where information cannot be obtained, the matter may need to be escalated to the Compliance Officer for further assessment. 

5. Independent Evaluation of Your AML/CTF Program 
 Your AML/CTF Program must also undergo an Independent Evaluation.
 

An Independent Evaluation is different from your regular internal review. An appropriately independent person must assess whether your AML/CTF Program, risk assessment, policies and controls are appropriately designed and are actually operating in practice. 

For newly regulated businesses, AUSTRAC has staggered the deadline for the first Independent Evaluation based on the last two digits of your AUSTRAC Account Number (AAN).

Example: 
If your AAN ends in 35, both numbers are odd, so your first Independent Evaluation must be completed by 30 June 2029. 

Your AML/CTF policies must also specify how frequently Independent Evaluations will occur. They must be conducted at least once every three years, with the frequency appropriate to the nature, size and complexity of your business. 

There is no need to wait until the deadline. Businesses may choose to conduct an evaluation earlier to identify and address compliance gaps. 

AML Guardian will introduce functionality to help track your Independent Evaluation requirement and deadline based on your AAN. 

6. What Should You Do Now? 

We recommend that customers take the opportunity to review their AML Guardian account and make sure the following are up to date: 

✅ AML/CTF Program approved 
✅ Business Risk Assessment completed and approved 
✅ Compliance Officer appointed 
✅ Relevant staff have completed AML/CTF training 
✅ Customer KYC/KYB checks are being completed 
✅ Customer risk assessments are being performed 
✅ High-risk customers are being appropriately reviewed 
✅ Compliance decisions and supporting evidence are being recorded 

There is no need to make major changes to your AML Guardian configuration at this stage. 

7. AML Guardian Enhancements Coming in September 

In September 2026, we will introduce several enhancements to AML Guardian to make it easier to manage the updated requirements. 

You can expect improvements across areas including: 

• Compliance Deadlines 
  Updated annual reporting dates, reminders and compliance milestones. 
• Customer Risk & CDD 
  Improved onboarding workflows to help identify and manage customer risk earlier. 
• Real Estate Counterparty CDD 
  Improved tracking of counterparty checks, due dates and follow-up activities. 
• Compliance Monitoring 
  Better visibility of overdue CDD, training, reviews and other compliance activities. 
• Reporting & Case Management 
  Enhancements to help Compliance Officers document decisions, suspicious activity assessments and supporting evidence. 
• Compliance Health 
  Improved visibility of how your AML/CTF Program is being implemented across your organisation. 

We will provide further information and guidance as each enhancement is released. 

8. What This Means for AML Guardian Customers 

Our objective is to continue translating regulatory requirements into simple, practical workflows. 

Rather than expecting businesses to manually track every AML/CTF requirement, AML Guardian will continue to provide reminders, workflows, evidence capture and reporting to help your organisation manage its compliance obligations. 

We will keep monitoring AUSTRAC guidance and update AML Guardian as requirements evolve. 

If you have any questions about how to use AML Guardian, please contact our team or reach out through the support options available within the platform. 

Disclaimer: AML Guardian is a technology platform designed to assist businesses in managing their AML/CTF compliance processes. Information provided by Syntrico is general in nature and should not be considered legal advice. Businesses remain responsible for understanding and meeting their own regulatory obligations.