Guide to Enrolling & Registering with AUSTRACT for Australia Businesses Providing Designated Services

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Introduction

For businesses in Australia offering designated services, understanding the requirements to enrol or register with the Australian Transaction Reports and Analysis Centre (AUSTRAC) is essential. Compliance with Australia’s anti-money laundering and counter-terrorism financing (AML/CTF) obligations, primarily governed by the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), is not just a legal necessity but also crucial for contributing to a safer financial system and mitigating risks associated with financial crime.

This guide provides a comprehensive overview for service providers navigating the AUSTRAC enrolment and registration processes. It clarifies who must enrol with AUSTRAC, the distinction between enrolment and registration (particularly for remittance and digital currency exchange providers), and why these steps are mandatory for businesses that provide designated services.

Understanding AUSTRAC Enrolment & Registration for Your Business

What is AUSTRAC?

AUSTRAC is Australia’s financial intelligence agency and the regulator responsible for enforcing the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).

This agency serves multiple critical functions:

• Overseeing compliance with AML/CTF laws by monitoring financial transactions
• Detecting and preventing money laundering, terrorism financing, and other serious crimes
• Collecting and analysing financial data from designated service providers
• Connecting Australian businesses to a global network of financial intelligence units

AUSTRAC supports national and international efforts to combat financial crime through these activities.

Defining Enrolment vs Registration

Enrolment and registration are two distinct but related processes required by AUSTRAC for businesses providing designated services:

Enrolment is mandatory for all reporting entities that provide designated services under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth). This process involves:

• Notifying AUSTRAC that your business offers these services
• Creating an AUSTRAC Online account
• Submitting the AUSTRAC Business Profile Form (ABPF), which includes details about your:
  • Business structure
  • Services offered
  • Key personnel
  • Contact information

Registration is an additional mandatory step required specifically for certain service providers:

• Remittance service providers
• Digital currency exchange (DCE) providers

After enrolment, these businesses must complete a separate registration process via AUSTRAC Online before they can legally operate. Registration requires:

• Submitting further information, including official police certificates for key personnel
• Obtaining AUSTRAC’s formal approval

It is important to note that while all designated service providers must enrol, only remittance and DCE providers must also register. Providing these specific services without confirmed registration is illegal and subject to penalties.

Why Enrolment and Registration are Mandatory

Enrolment and registration with AUSTRAC are essential for several key reasons:

Compliance with AML/CTF Laws: These processes ensure businesses comply with Australia’s AML/CTF regulations. This compliance helps:

• Safeguard the integrity of the financial system
• Protect businesses from legal risks

Crime Prevention and Risk Mitigation: By enrolling, businesses become part of a collaborative network that:

• Assists law enforcement agencies in identifying illicit financial activities
• Supports investigations into money laundering, terrorism financing, and organised crime
• Helps disrupt criminal financial operations

Operational Resilience and Marketplace Trust: Compliance with AUSTRAC’s requirements:

• Strengthens a business’s operational resilience through robust AML/CTF programs
• Builds trust with customers, partners, and regulators
• Demonstrates commitment to regulatory standards

Protecting Reputation and Financial Interests: Proper enrolment and registration:

• Reduce the risk of exposure to financial crime
• Minimise potential reputational damage
• Demonstrate ethical practices and due diligence
• Can enhance a business’s standing in the marketplace

Contributing to a Safer Financial Ecosystem: Enrolled and registered businesses help:

• Maintain a secure and transparent financial environment
• Prevent illicit funds from entering the Australian financial system
• Protect both local and international markets

Failure to enrol or register as required can result in significant penalties, including fines and legal sanctions. Businesses must enrol within 28 days of starting to provide a designated service and complete registration before offering remittance or DCE services.

For newly regulated services under Tranche 2 reforms, specific deadlines apply:

• 29 July 2026 for enrolment
• 31 March 2026 for virtual asset service registration

Who Must Enrol or Register with AUSTRAC?

Determining if You Provide Designated Services (Enrolment)

Your business must enrol with AUSTRAC if it provides any ‘designated services’ as outlined in the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth). Enrolment is mandatory for all reporting entities, signifying that your business is part of Australia’s AML/CTF framework. You are required to complete this enrolment within 28 days of starting to provide a designated service.

Designated services cover various activities identified as potentially vulnerable to money laundering or terrorism financing. To determine if you need to enrol, check if your business offers services such as:

• Financial Services: Including account services, loans, issuing debit cards, financial planning related to arranging designated services, superannuation fund management, foreign currency exchange, and custodial services.
• Remittance Services: Transferring money or value on behalf of customers.
• Digital Currency Exchange / Virtual Asset Services: Exchanging virtual assets for money or other virtual assets, transferring virtual assets, or providing safekeeping services like digital wallets.
• Gambling Services: These include operating betting accounts, exchanging gaming chips, or paying winnings.
• Bullion Dealing.
• Tranche 2 Services (Newly Regulated):
  • Real Estate and Conveyancing: Brokering property sales, selling property directly (e.g., developers), or assisting with real estate transactions.
  • Legal, Trust, and Company Services: Assisting with buying/selling legal entities, managing client funds in transactions, arranging financing, selling shelf companies, creating or restructuring entities, or acting in certain capacities like director or trustee.
  • Precious Metals and Stones Dealers: Accepting cash or virtual assets of $10,000 or more for precious items like jewellery or watches.

Identifying Services Requiring Additional Registration

While all businesses providing designated services must enrol, certain service providers face an additional, mandatory step: registration. This registration must be completed after enrolment before commencing with the specific services.

The businesses requiring this extra registration step are:

• Remittance service providers: This includes independent remittance dealers and, in some cases, their affiliates.
• DCE providers: These are also referred to as virtual asset service providers.

It is crucial to understand that providing remittance or DCE services without being registered with AUSTRAC is against the law. Penalties may apply if you offer these services before AUSTRAC formally confirms your registration. Businesses providing virtual asset services have a specific deadline: they must be registered before 31 March 2026.

If your business operates as a remittance network provider affiliate, your network provider is typically responsible for registering your business with AUSTRAC. You generally only need to register yourself if you operate as an independent remittance service provider.

Step-by-Step Guide to Enrolling with AUSTRAC

Preparing Information for the AUSTRAC Business Profile Form

Before starting the enrolment process with AUSTRAC, gathering all necessary information to complete the ABPF is essential. Having these details ready will help streamline the online submission via AUSTRAC Online.

You will need to provide comprehensive details about your business and its operations, including:

• Business Identification: Your business’s legal and trading names and relevant registration numbers, like your Australian Business Number (ABN) or Australian Company Number (ACN).
• Business Structure: Information about the legal structure of your business, such as whether it operates as a sole trader, company, partnership, or trust.
• Contact Information: Current contact details for the business, including the principal place of business address, postal address, phone number, and business email address.
• Designated Services: Details about the designated services your business provides or intends to provide under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).
• Key Personnel: The full names, dates of birth, positions held (e.g., directors, senior managers, compliance officer), and contact details for individuals in key roles within the business.
• Financial Information: Financial statements for the most recent financial year may be required.
• Foreign Registration: Details of any business registration in a foreign country, if applicable.
• Legal History: Information regarding any relevant criminal, civil, or enforcement actions related to the business or its key personnel, particularly money laundering, terrorism financing, fraud, or other serious offences.

Completing & Submitting the AUSTRAC Business Profile Form via AUSTRAC Online

The enrolment process is completed electronically using the ABPF through the AUSTRAC Online portal. You can access the form directly via the portal or through the enrolment page on the AUSTRAC website.

Follow these steps to complete and submit the form:

1. Access the Form: Navigate to the ABPF on the AUSTRAC Online platform.
2. Verify Email: You must provide a valid business email address. AUSTRAC will send a verification link to this address, which you should click to continue the form. This email address will also be used for your AUSTRAC Online account.
3. Fill in Details: Complete all required sections of the form using the information you prepared. Incomplete sections will be clearly marked.
4. Save Progress: If you cannot complete the form in one session, you can save your progress. A link will be emailed to you, allowing you to return to the saved form for up to 14 days (two weeks) before it expires and is deleted.
5. Review Information: Review all the information in the summary section before submitting. Use the ‘Edit’ function to correct any inaccuracies.
6. Declaration: Read the declaration statement carefully. If you agree, tick the ‘I agree’ box.
7. Submit: The ‘SUBMIT’ button will activate once you agree to the declaration. Click it to submit the form electronically to AUSTRAC.
8. Confirmation: Upon submission, a receipt number will be displayed on the screen; note this for your records. You will also receive a confirmation email containing the receipt number and a link to download a copy of your completed ABPF.

After submission, AUSTRAC will process your enrolment application and may contact you if further information is needed. Once processed, you will receive another email with details on accessing your AUSTRAC Online account.

Enrolment Timeline

Businesses that provide designated services must enrol with AUSTRAC promptly. The standard requirement is to complete enrolment within 28 days of starting to provide a designated service.

A specific deadline applies for businesses newly captured under regulations, such as those affected by the Tranche 2 reforms (including certain real estate, legal, trust, and company service providers). These entities must complete their enrolment with AUSTRAC by 29 July 2026.

Step-by-Step Guide to Registering with AUSTRAC (Remittance and Digital Currency Exchange/Virtual Asset Providers)

The Registration Process via AUSTRAC Online

After successfully enrolling your business, the next step for remittance service providers and DCE providers is to complete the mandatory registration process through your AUSTRAC Online account.

To initiate registration:

1. Log in to your AUSTRAC Online account using the credentials provided after enrolment.
2. Navigate to the specific registration form, often under sections like ‘Remittance Sector Register’ or similar links for DCE providers.
3. If you manage multiple businesses, select the correct one to register.
4. Complete the registration form. Some details will be pre-filled from your enrolment application (ABPF); verify these carefully.
5. Fill in all required sections specific to remittance or DCE operations.

Required Documentation (Including Police Checks)

A critical part of the registration process involves submitting official police documents for each key person within your business. This requirement helps AUSTRAC assess the suitability of individuals involved in these specific service sectors.

The acceptable documents include:

• A National Police Certificate
• A foreign equivalent of a National Police Certificate
• A National Police History Check

These police documents must have been issued recently, typically within six months of the date you submit your registration application to AUSTRAC. Ensure you gather these documents well in advance to avoid delays.

Registration Timeline and Approval

Once you submit your registration application via AUSTRAC Online, AUSTRAC begins its assessment process. This assessment can take up to 90 days to complete.

During this period, AUSTRAC may contact you to request additional information or clarification regarding your application. It is crucial to respond promptly to any such requests.

Most importantly, you must not provide remittance or DCE services until AUSTRAC formally confirms your registration in writing. Operating these services without confirmed registration is against the law and may result in significant penalties.

Special Considerations for Affiliates

The registration process usually differs if your business operates as a remittance network provider affiliate. Your registered network provider is typically responsible for registering your business with AUSTRAC.

You generally only need to register independently if you provide remittance services outside your affiliate arrangement (as an independent remittance service provider).

Your network provider will handle the submission of required police documents for both their key personnel and yours. However, the timeframe needed for your personnel’s documents may differ slightly (e.g., issued within twelve months). Contact your network provider directly to understand their process.

Tips for a Smooth Enrolment & Registration Process

Prepare Documentation in Advance

Gathering all necessary documents and information before starting the online enrolment or registration forms can make the process smoother and faster. Ensure you have key details readily available. This includes:

• Your business’s legal and trading names and ABN or ACN.
• Details about your business structure (e.g., sole trader, company, partnership).
• Current contact information for the business.
• Specifics about the designated services you provide or intend to provide under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).
• Full names, contact details, and positions for key personnel like directors and senior managers.
• Recent financial statements, if required.
• Details of any foreign registrations.
• Information on any relevant criminal, civil, or enforcement history concerning the business or key personnel.
• For registration (remittance/DCE providers), official police documents for key personnel must be issued within the required timeframe (usually six months).

Don’t Delay Submission

Starting the enrolment or registration process early is highly advisable. Procrastinating until close to deadlines can lead to unnecessary stress and potential issues.

Submitting your application well in advance provides ample time to resolve any queries or problems that might arise during the process. It also helps avoid delays caused by high traffic volumes on AUSTRAC’s online systems during peak periods. Remember the key deadlines:

• Enrolment must generally occur within 28 days of providing a designated service.
• Specific dates like 29 July 2026 apply to newly regulated entities.

Verify Information Carefully

Accuracy is crucial when completing the ABPF and subsequent registration forms. Mistakes in your submitted information can lead to significant delays in processing your application.

Take the time to double-check all details before submission. Pay particular attention to:

• Your ABN or ACN.
• The legal structure of your business.
• The names and contact details provided for key personnel associated with the company.

Utilise AUSTRAC’s Support Resources

AUSTRAC provides various resources to assist businesses in navigating the enrolment and registration requirements. Familiarising yourself with these tools can help clarify the process and prevent confusion.

Available support includes:

• Explanatory Guides: The detailed ABPF explanatory guide offers step-by-step instructions.
• Quick Reference Guides: Concise guides are available for enrolling and registering a business.
• FAQS: AUSTRAC’s website often features frequently asked questions that address common issues.
• Contact Centre: If you encounter technical difficulties with forms or have specific questions, you can contact AUSTRAC directly via email or phone.

Consider Professional Advice

While AUSTRAC offers guidance, the complexities of AML/CTF compliance can sometimes be challenging. If you feel uncertain about any aspect of the enrolment or registration process, or your business situation is complex, seeking external help is a sensible option.

Consider engaging with professionals who specialise in AML/CTF compliance, such as:

• Compliance consultants with experience in AUSTRAC requirements.
• Legal professionals who can provide tailored advice based on your specific circumstances.

Stay Informed About Updates

The regulatory landscape for AML/CTF can evolve. It is crucial for businesses providing designated services to stay informed about any changes that might affect their obligations or the enrolment and registration process itself.

AUSTRAC regularly communicates updates and provides information through various channels. To stay current:

• Subscribe to AUSTRAC’s newsletters for direct updates.
• Regularly check the official AUSTRAC website, particularly the AML/CTF reform sections, for new guidance or announcements (like the planned form updates in November 2024).
• Engage with your relevant industry association, as they often work closely with AUSTRAC and share pertinent information.

Maintaining Compliance After Enrolment and Registration

Developing and Maintaining an Anti-Money Laundering and Counter-Terrorism Financing Program

Successfully enrolling or registering with AUSTRAC is the first step; ongoing compliance is crucial. All reporting entities must develop, implement, and maintain an AML/CTF program tailored to their business risks.

This program is the foundation for meeting your obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth). Your AML/CTF program must outline how your business identifies, mitigates, and manages its money laundering and terrorism financing (ML/TF) risks.

Key components of an effective AML/CTF program typically include:

• Conducting thorough ML/TF risk assessments specific to your operations
• Establishing clear policies and procedures for customer due diligence (often referred to as ‘know your customer’ (KYC))
• Implementing systems for ongoing transaction monitoring
• Providing regular AML/CTF training for staff
• Maintaining accurate records as required by law
• Arranging for independent reviews of the program

Additionally, businesses often should appoint a dedicated AML/CTF Compliance Officer. This individual oversees the AML/CTF program and ensures the company meets all relevant compliance requirements.

Reporting Obligations

Reporting entities have mandatory reporting obligations to AUSTRAC, which must be submitted through the AUSTRAC Online portal. Timely and accurate reporting is essential for compliance and contributes vital information to Australia’s financial intelligence efforts.

Key reports that businesses may need to submit include:

• Suspicious Matter Reports (SMRs): These are submitted when you form a suspicion regarding potential money laundering, terrorism financing, or other serious crimes related to your services
• Threshold Transaction Reports (TTRs): Required for physical cash transactions of A$10,000 or more (or the foreign currency equivalent)
• International Funds Transfer Instruction (IFTI) reports: Necessary for instructions sent into or out of Australia
• Annual AUSTRAC Compliance Reports: Submitted each year, detailing your compliance activities for the previous calendar year

Keeping Details Updated

It is a legal requirement to keep the information AUSTRAC holds about your business current. You must promptly notify AUSTRAC of any changes to your business details using your AUSTRAC Online account.

Ensure you update AUSTRAC regarding changes to:

• Your business’s legal or trading names
• Your contact details (address, phone, email)
• Your business structure (e.g., changing from a sole trader to a company)
• The designated services you provide
• Key personnel, such as directors, senior managers, or your AML/CTF compliance officer

Failure to update your details can hinder communication and lead to compliance issues.

Registration Renewal (Remittance/Digital Currency Exchange)

Registration is not permanent for businesses registered specifically as remittance service providers or DCE providers. These registrations typically need to be renewed every three years.

AUSTRAC usually sends reminders before the registration expiry date. However, the business is responsible for ensuring renewal is completed on time via AUSTRAC Online to legally continue providing remittance or DCE services. Operating these services with an expired registration is an offence.

Conclusion

This guide outlined the essential steps for businesses providing designated services to enrol and, where necessary, register with AUSTRAC, highlighting the mandatory nature of these processes for compliance with Australia’s AML/CTF laws. Maintaining ongoing compliance through robust AML/CTF programs, diligent reporting, and keeping business details current is crucial after completing the initial requirements.

Navigating these complex regulatory requirements can be challenging, but ensuring compliance is vital for your business’s integrity and security. For specialised assistance in meeting your AUSTRAC obligations and transforming compliance challenges into strategic advantages, contact the experts at AML House today for tailored legal and consulting services.

Frequently Asked Questions