CPS 230: What Your Firm Must Do
What changed on 1 July 2025
Australia extended its AML/CTF regime to "Tranche 2" businesses — roughly 90,000 firms that were previously outside AUSTRAC's scope. If you provide a designated service, you must enrol with AUSTRAC, maintain an AML/CTF program, conduct customer due diligence, and report suspicious matters.
Who is captured — and what triggers it
Triggers: All material outsourcing arrangements, offshore arrangements, cloud services.
Triggers: Claims processing outsourcing, IT cloud, actuarial services.
Triggers: Administration outsourcing, investment management, custody.
Triggers: Portfolio management, platform services, custodial services.
Full list of designated services: AUSTRAC's entityTypeal designated services guidance.
Key dates
- 1 July 2025 — Tranche 2 reforms commence.
- 29 July 2026 — enrolment deadline for newly regulated legal practitioners (and equivalent entities).
- 1 July 2029 — first possible extensions under AUSTRAC transitional rules for Tranche 2 entities.
Your core obligations
- Enrol with AUSTRAC (free, mandatory).
- AML/CTF program — Part A (risk-based) and Part B (customer identification).
- Customer due diligence — identify and verify customers, beneficial owners; ongoing monitoring.
- Reporting — suspicious matter reports (SMRs) and international funds transfer instructions (ITRs).
- Record-keeping + training + independent review of your program.
What does it cost?
Government analysis estimated average ongoing costs of ~$23,250/year per business; firms with turnover under $200,000 face ~$4,040 upfront and ~$6,020/year. Your actual number depends on firm size and approach.
Estimate your costs with the calculator →