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Regulator watch 1 May 2026 7 min read

What to do in the first 48 hours when AUSTRAC engages

A practical playbook for the moment a compliance assessment letter, RFI, or notice arrives — without panicking your firm.

By James Carter

AUSTRAC engagement starts politely. The first contact is almost always a letter or an email requesting documents — not an unannounced visit. How you handle the first 48 hours sets the tone for the entire engagement.

Hour 0–4: stop, read, and acknowledge

  • Read the letter twice. Identify exactly what is being requested and the deadline.
  • Acknowledge receipt to AUSTRAC the same day, even if the full response is weeks away.
  • Notify your AML compliance officer, your senior partner or director, and your insurance broker.
  • Do not start mass-emailing staff — circulation creates noise and risk.

Hour 4–24: assemble the audit pack

Most AUSTRAC requests can be answered with a standard audit pack: current Part A and Part B program, latest risk assessment, training records, sample CDD files across risk tiers, SMR/TTR register, last independent review, and evidence of board oversight. If your AML platform can export this on demand (most can), the first 24 hours is a tidy-up exercise — not a scramble.

Hour 24–48: scope the response

  • Map every request to a specific document or evidence item.
  • Identify gaps honestly — do not pad weak evidence.
  • Decide whether to engage external AML counsel (worth it if the request mentions a specific transaction or customer).
  • Draft your response with version control; treat every word as discoverable.

What not to do

  • Do not amend program documents to look better than they were on the relevant date.
  • Do not destroy or 'tidy up' records after the request arrives.
  • Do not engage with AUSTRAC informally outside the documented response channel.
  • Do not assume silence means the matter is closed — confirm closure in writing.
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