AUSTRAC has started writing tickets to accountants and jewellers

Around 100,000 small firms came under anti-money laundering law on 1 July. The infringement notices began at the end of September, at A$21,840 a time.

The grace period is over. The Australian Transaction Reports and Analysis Centre (AUSTRAC) confirmed on 30 September that it had begun issuing infringement notices to businesses that failed to enrol under the expanded anti-money laundering regime, with penalties of A$21,840 for a company and A$4,368 for an individual.

The reforms, which commenced on 1 July, extend the Anti-Money Laundering and Counter-Terrorism Financing regime to accountants, lawyers, conveyancers, real estate agents, trust and company service providers and dealers in precious metals and stones when they provide designated services. Charles Sturt University financial crime researcher Michael King estimates the change brings roughly 100,000 additional businesses under AUSTRAC's oversight. Those captured must enrol, assess their money laundering risk, run customer due diligence, maintain a compliance program and report suspicious matters.

AUSTRAC's position is that the sector has largely complied. Deputy Chief Executive Officer for Regulation Katie Miller says around 90 per cent of organisations identified as at risk of not enrolling have since enrolled or taken active steps to do so, and that consequences follow for the small minority who continue to disregard the obligations. On the question of proportionality, Miller is direct: the law applies when a business provides a designated service, and the size of the business does not change that.

The complaint from the sector is not that the obligations are unreasonable in principle but that they were built for banks. Council of Small Business Organisations Australia chair Matthew Addison, who also runs the Institute of Certified Bookkeepers, argues a one-person suburban practice carries a burden a Big Four firm absorbs with a dedicated team, and that third-party compliance software adds another cost on top. 

King has warned the expanded regime could push smaller firms to close, merge or simply stop offering regulated services, and has questioned whether an enforcement framework designed for the largest banks suits a small accounting practice.

That withdrawal is already visible. Addison says some professional advisers are narrowing the range of services they are prepared to offer. Jewellers have an explicit off-ramp: those who decline cash or virtual asset payments of A$10,000 or more, and provide no other designated service, can avoid certain obligations entirely. The Law Council of Australia has pointed to New Zealand, where some firms stopped offering regulated services or shut after equivalent reforms.

Addison acknowledges AUSTRAC has worked to make compliance simpler for straightforward firms, including clarifying when bookkeepers need not enrol. His point is that the residual burden still falls unevenly.

If you are captured and have not enrolled, enrolling today is still cheaper than the notice. Work out precisely which of your services are designated, because the answer is usually narrower than firms assume and it determines everything that follows. Then build the program at the scale of your actual risk rather than buying the enterprise software package a vendor is selling you. AUSTRAC has said it expects effort rather than perfection, and year one enforcement is clearly aimed at non-enrolment rather than imperfect record keeping. That will not hold. Expect the second wave of enforcement, through 2027, to target the firms that enrolled and then did nothing, which is a much larger group than the one getting notices now.