AML/CTF Updates: What Clubs Need to Know

While many changes target new or higher‑risk sectors, existing reporting entities — including clubs — should understand recent developments and ensure core compliance obligations are up to date.

Below is a summary of recent AML/CTF-related announcements.

AUSTRAC’s new compulsory examination powers

AUSTRAC has published guidance explaining how it will use its new compulsory examination powers, introduced under changes to the AML/CTF Act in 2025. These allow AUSTRAC to require a person to attend an examination, answer questions and provide documents where needed.

AUSTRAC has made it clear these examinations are not routine or punitive. They will be used where necessary to better understand money‑laundering risks, clarify information or assess how a business is managing its AML/CTF obligations.

Importantly, receiving a notice does not mean a law has been broken, and individuals can have legal representation.

The guidance is intended to provide clarity about when and how AUSTRAC may exercise these powers.

New professions brought into the AML/CTF regime

From 31 March 2026, AUSTRAC opened enrolment for new professions (including lawyers, accountants and real estate professionals), with full obligations starting 1 July 2026.

AUSTRAC has also updated enrolment requirements for existing reporting entities, including clubs. These updates may require entities to submit updated details like designated services, reporting group details and AML/CTF compliance officer contact information.

Proliferation financing is now formally captured

New Proliferation Financing Regulations commenced on 31 March 2026. The new regulations now explicitly cover proliferation financing (linked to weapons of mass destruction).

For most clubs, proliferation financing risk is expected to be very low, but the requirement to consider and document this risk still applies.

Transitional rules to support the reforms

The Minister for Home Affairs made the AML/CTF Transitional Rules under the AML/CTF Act to support the implementation of the reformed AML/CTF framework. These rules provide phased timeframes for certain obligations, including aspects of customer due diligence, reporting changes and independent reviews.

Clubs should use this transition period to:

• Review and update AML/CTF programs
• Refresh risk assessments (including proliferation financing)
• Put clear implementation plans in place so new requirements are embedded well before transition deadlines

The intent is to support compliance while ensuring money‑laundering and terrorism‑financing risks continue to be managed.

Proposed new AML/CTF powers under parliamentary review

The Parliamentary Joint Committee on Intelligence and Security (PJCIS) is reviewing proposed amendments to the AML/CTF Act that would give AUSTRAC additional powers to combat money laundering and terrorism financing.

The proposed changes would allow AUSTRAC to restrict or prohibit reporting entities from using certain high‑risk mechanisms to provide designated services and update elements of terrorism‑financing offences. These proposals are not yet law, but aim to ensure the AML/CTF framework keeps pace with emerging financial crime risks.

Virtual asset service provider (VASP) register

AUSTRAC has published a searchable public register of registered cryptocurrency businesses after removing inactive and dormant entities. The aim is to improve transparency and make it harder for criminals to misuse registered businesses to launder money.

The crypto sector remains a high‑risk focus for AUSTRAC, but these changes do not introduce new obligations for clubs.

Review of criminal intelligence reforms underway

Separately, the PJCIS has begun reviewing proposed reforms to the Australian Criminal Intelligence Commission. While this review does not change club obligations, it forms part of the broader effort to strengthen Australia’s response to serious and organised crime.

Compliance reminder for clubs

Clubs must continue to meet their existing AML/CTF obligations, including:

• Keeping AML/CTF programs and risk assessments up to date
• Ensuring compliance officer details are current
• Submitting required reports to AUSTRAC

ClubsNSW will continue to monitor developments and provide practical guidance as reforms continue to roll out.

If you have any questions, contact ClubAssist on 1300 730 001 or [email protected].