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Regulator watch 12 April 2026 9 min read

AUSTRAC enforcement trends: what penalties have been issued and why

What recent enforcement action tells us about how AUSTRAC will likely supervise Tranche 2 reporting entities.

By Sophie Maddox

AUSTRAC's enforcement record over the last decade has focused on Tranche 1 reporting entities — banks, remitters, and gambling operators. The civil penalties have been substantial: Westpac (A$1.3 billion), Crown (A$450 million), CBA (A$700 million). The pattern across these cases is consistent, and instructive for Tranche 2 firms.

What the enforcement actions have in common

  • Failure to identify and assess risk at the program level — not isolated failures.
  • Failure to act on red flags that staff had identified internally.
  • Inadequate or backdated SMRs and TTRs.
  • Inadequate independent review and remediation of identified weaknesses.
  • Failure to escalate to senior management and the board.

What this means for Tranche 2

AUSTRAC began issuing section 167 notices to unenrolled businesses in August 2026.

How to be the firm AUSTRAC engages constructively with

  • Have a written program that names a real person as compliance officer.
  • Be able to evidence CDD on every in-scope client.
  • Have an audit log showing your monitoring is actually running.
  • File at least one SMR or be able to evidence why you have not.
  • Have an independent review scheduled.
Practical next step

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