Enrolled With AUSTRAC? October Shows What Comes Next

For tens of thousands of Australian businesses, 2026 was the year anti-money laundering law arrived at the front door. Since 1 July, real estate agents, lawyers, accountants, conveyancers, trust and company service providers and dealers in precious stones and metals have had obligations under the AML/CTF Act. For most of them, the first task was AUSTRAC enrolment.

October showed what comes after that first step. In the space of four weeks, AUSTRAC began fining Tranche 2 businesses that had not enrolled, and the Federal Court ordered The Star to pay $260 million for running an AML/CTF program that did not work in practice. In our 25+ years supporting compliance teams across South Africa, Australia and global markets, we have seen this sequence before: regulators start with the basics, then move quickly to whether controls actually hold up.

Key Takeaways

• AUSTRAC has started fining unenrolled Tranche 2 businesses, with infringement notices of $21,840 for companies and $4,368 for individuals that can accrue daily.
• AUSTRAC enrolment is only the first step. Enrolled businesses must also assess their risks, run an AML/CTF program and put working controls in place.
• The Star’s $260 million penalty shows what happens when a program exists on paper but customers are not properly checked or monitored.
• The lessons apply well beyond casinos: know your customer, know where the money comes from, and keep watching after onboarding.

AUSTRAC Enrolment: The First Fines Have Landed

Tranche 2 businesses providing a designated service from 1 July 2026 had to enrol with AUSTRAC by 29 July. In August, AUSTRAC sent formal requests for information to businesses that appeared to be providing designated services without having enrolled. On 30 September it moved to enforcement.

According to AUSTRAC’s announcement, the first infringement notices went to businesses in the real estate, accounting and jewellery sectors that it believes failed to enrol within 28 days of providing a designated service. The notices were issued at $21,840 for corporate entities and $4,368 for individuals, and can accrue daily.

AUSTRAC CEO Brendan Thomas said around 90 per cent of the businesses it first had concerns about have now enrolled or attempted to enrol, and that more notices will follow where needed. His message was direct: “Enrolment is a simple first step, and there is no excuse for failing to take it.”

The important words there are “first step”. AUSTRAC was just as clear that businesses covered by the law must be taking steps to understand their obligations, assess their risks and put appropriate controls in place. Being on the roll tells AUSTRAC who you are. It does not tell AUSTRAC that your controls work.

The Star: What a Program That Fails in Practice Costs

On 28 October, the Federal Court ordered The Star Entertainment Group to pay $260 million after finding it failed to maintain a compliant AML/CTF program and failed to monitor customers to identify, mitigate and manage money laundering and terrorism financing risks. The Star has said it will pay the penalty in four instalments over 19 months.

The contraventions centred on high-risk customers. The Court found failures to verify customer information and source of funds, to conduct appropriate due diligence and to monitor customer activity, including third-party transactions and cash deposits where the third party’s identity was not recorded. More than 1,200 customers were able to gamble through channels carrying high money laundering and terrorism financing risk.

Brendan Thomas summed up the finding: The Star “did not simply fail to complete the right checks. It allowed high-risk customers to gamble without properly establishing where their money came from.”

Why a Casino Case Matters to Tranche 2 Businesses

It would be easy for a suburban real estate agency or a three-partner accounting firm to read the Star case as a story about casinos. It is not. The obligations The Star breached are the same core obligations every Tranche 2 business now carries: a program that reflects your real risks, customer due diligence that goes beyond collecting a name, and ongoing monitoring once the relationship has started.

The risks are not so different either. A property settlement funded by an unexplained third party, a trust structure set up for a client whose wealth does not add up, or a high-value cash purchase of jewellery all raise the same question the Court asked of The Star: where did the money come from, and did anyone check?

Read together, October’s two announcements describe AUSTRAC’s path for Tranche 2. Enrolment first. Then the quality of your program and whether it is actually followed.

Five Checks to Run After AUSTRAC Enrolment

If your business has completed its AUSTRAC enrolment, these are the questions to answer next. Each one comes straight from the findings above.

1. Is your AML/CTF program specific to your business? A template program that does not reflect your services, clients, channels and locations will not survive scrutiny. Start with a documented money laundering and terrorism financing risk assessment, then build controls that match it. Our post on making Tranche 2 compliance easier with the COMFORT Score shows how consistent risk scoring helps.

2. Do you know who you are really dealing with? Customer due diligence means verifying identity and, for companies and trusts, identifying the individuals who own or control them. Know Your Business checks map company structures to the people behind them.

3. Are you screening for PEPs and sanctions? Every new customer should be checked against sanctions lists, including the DFAT Consolidated List, and for politically exposed person status. HLBNGA’s sanctions screening and PEP screening do this in seconds, with an audit-ready record of every check.

4. Can you show where the money comes from? This was the heart of the Star case. Higher-risk customers need enhanced customer due diligence, including source of funds and source of wealth, documented in the file. KYCopilot produces structured enhanced due diligence reports in minutes, so deeper checks are consistent rather than left to individual judgement.

5. Do your checks continue after onboarding? The Star’s monitoring failures meant, in AUSTRAC’s words, that “we cannot know how much money high-risk customers pumped through its casinos”. RiskSecure 360 monitors existing customers continuously and alerts you when their sanctions, PEP or adverse media status changes.

Behind all five sits your team. Staff need to know what a red flag looks like and when to escalate it. KAT builds and assigns AML/CTF training, tracks completion and keeps the evidence ready for when AUSTRAC asks.

Built for Tranche 2 Sectors

Most Tranche 2 businesses do not have a compliance department, and they should not need one to meet their obligations. HLBNGA works with real estate agencies, law firms and conveyancers and accounting practices to make screening, due diligence and monitoring part of the normal client intake, not an extra job at the end of it.

AUSTRAC has made its sequence clear. AUSTRAC enrolment was the entry ticket. The businesses that will be comfortable at the next stage are the ones that can show, client by client, that their program is followed.

Frequently Asked Questions

What is AUSTRAC enrolment?

AUSTRAC enrolment is the process of registering your business with AUSTRAC as a reporting entity. A business that provides a designated service under the AML/CTF Act must enrol within 28 days of first providing that service.

Which businesses must enrol under Tranche 2?

Since 1 July 2026, businesses providing designated services in sectors such as real estate, legal services, accounting, conveyancing, trust and company services, and dealing in precious stones and metals must enrol with AUSTRAC.

What is the penalty for not enrolling with AUSTRAC?

AUSTRAC has issued infringement notices of $21,840 for companies and $4,368 for individuals, which can accrue daily. It can also take more serious action, including civil penalty proceedings in the Federal Court.

Is enrolling with AUSTRAC enough to comply?

No. Enrolment is the first step. Reporting entities must also assess their money laundering and terrorism financing risks, maintain an AML/CTF program, conduct customer due diligence, monitor customers, report suspicious matters and keep records.

HLBNGA helps Tranche 2 businesses screen, verify and monitor every client, with the evidence to prove it. Talk to us about getting your program ready for AUSTRAC’s next step.