What the Act allows
- Civil penalties for failing to enrol, operating without a program, failing to carry out due diligence or failing to report; maximums in the tens of millions for a company.
- Enforceable undertakings, remedial directions and infringement notices for lesser or first breaches.
- Criminal offences for tipping off.
What has happened so far
AUSTRAC's headline actions have been against large institutions, such as AU$1.3 billion against Westpac in 2020 and AU$450 million against Crown Resorts in 2023, for systemic failures over years.
What small firms should expect
AUSTRAC has said it will support Tranche 2 entities with guidance and education, and prioritise enforcement against those that wilfully ignore the obligation to enrol or are wilfully blind to money laundering. The realistic risk is a compliance review that finds no program, no identification and no records, followed by a remedial direction, plus the professional conduct consequences with your law society or licensing body.
Questions people ask
- Can a principal be personally liable?
- Yes. Individuals, including the compliance officer and principals, can face civil penalties and, for tipping off, criminal liability.
Sources
Official AUSTRAC guidance this page was checked against. The date is when we captured the page; AUSTRAC may have updated it since.
- Enforcement actions taken · AUSTRAC, captured 16 May 2026
- Our regulatory expectations and priorities for 2025–26 · AUSTRAC, captured 01 May 2026
This guide is general information for solicitors, conveyancers, settlement agents, not legal advice. Check AUSTRAC's current guidance for your situation.