Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Reform Update

Overview

Since our last update on 1 December 2025, the landscape for navigating the AML Reforms has continued to evolve. In late January the Department of Home Affairs and AUSTRAC announced proposed transitional rules that would provide existing Reporting Entities with extended timeframes to implement certain new obligations under the reform.

 With the transitional rules currently being finalised, what does this mean for you, and what is Automic doing to prepare to support clients through these changes?

Key Takeaways

• • Three-year deemed compliance period for Initial Customer Due Diligence (ICDD)
    From 31 March 2026 to 31 March 2029, existing reporting entities may continue using their current Applicable Customer Identification
    
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  • Procedures (ACIP) for new investors.
    During this period, continuing to apply existing procedures will be taken as meeting the relevant ICDD obligations.
    
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  • First independent evaluation timing
    In certain circumstances, existing reporting entities will be granted an extended timeframe to undertake their first independent evaluation under the new regime.
    

It is important to note that for reporting entities providing designated services relating to managed funds, transitional relief does not apply to several other key elements of the reforms, which will still commence as scheduled.

Automic’s Preparations

Automic continues to work closely with our partner bronID, with our technical teams focused on delivering a smooth transition to the new Initial Customer Due Diligence procedures for Automic clients.

We currently expect to go live with the new ICDD procedures before the end of the current financial year.

In parallel, we are preparing documented procedures covering the key AML/CTF processes under the new AML/CTF regime, including:

• electronic verification
• document-based verification
• politically exposed person (PEP) and sanctions screening
• ongoing customer due diligence (OCDD)
• enhanced customer due diligence (ECDD)

These materials will be shared with clients as soon as possible, subject to any further guidance issued by AUSTRAC.

Considerations for Automic clients:

While the transitional arrangements provide flexibility for Initial Customer Due Diligence, they do not extend to the new Ongoing Customer Due Diligence obligations, which will become mandatory from 31 March 2026.

Accordingly, reporting entities will still have significant obligations commencing on this date and should continue progressing their AML/CTF framework review and uplift in preparation for the new regime. This includes:

Automic encourages clients to seek advice from their legal advisers or other consultants regarding how the reforms apply to their specific circumstances.

For matters relating to the AML/CTF services Automic provides, we are always available to discuss these changes with you and support your preparation for the new regime.