iscoverWith up to 90,000 new entities set to be regulated by AUSTRAC under new AML/CTF laws, a recruitment specialist has urged firms to prepare early to avoid resourcing crunches.
Avoid last-minute AML/CTF scramble, warns recruiter
19 September 2025
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10 minute read
Simon Rippon, a recruitment specialist at Momenta, has told sister brand Accounting Times firms that left AML/CTF compliance to the last minute could be left scrambling for talent and expertise by mid-next year.
From 1 July 2026, accounting firms that provide designated services, including assisting with real estate transactions and setting up trust and company structures, will be captured under AML/CTF rules as ‘Tranche 2’ entities.
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AUSTRAC, the financial intelligence unit enforcing Australia’s AML/CTF regime, currently regulates approximately 19,000 entities. After 1 July 2026, Rippon said this number would increase by an estimated 70,000 to 90,000.
The sharp uptick in regulated entities could lead to resourcing crunches as firms compete for AML/CTF expertise, Rippon warned. He said that firms that prepared well in advance would be best placed to remain compliant once the rules took effect.
“With the number of organisations that are going to need the same type of resource, the earlier firms make their decisions and implement those decisions, the better,” he said.
“When there is a scramble for resources between 70 to 90,000 newly regulated entities, the cost of those resources are potentially going to increase exponentially as it becomes a very, very competitive market with many firms vying for the same results and expertise.
“The biggest risk is scrambling at the last minute and ending up with the wrong person in the role.”
Under the new laws, Tranche 2 entities would be required to enrol with AUSTRAC, develop an AML/CTF program, conduct ongoing customer due diligence, report suspicious activities and maintain adequate records of their compliance activities.
Lawyer and anti-money laundering specialist Fiona Halsey told Accounting Times that the obligation to appoint a designated AML/CTF compliance officer would pose notable compliance burdens for accounting firms.
“That person has to have a reasonable knowledge of AML and CTF. And if you think of the sheer number of Australian accounting firms, if even half of them are caught by this, and they've all got to appoint an AML officer … it's huge,” Halsey said.
“It's really significant. And it feels to me as though accountants, on the whole, are not aware of what's coming.”
To fulfil new AML/CTF requirements, including the compliance officer role, Rippon predicted that some firms would choose to upskill existing staff. Others would hire a permanent AML/CTF specialist or fill the role through outsourcing. Each option offered pros and cons in terms of affordability and expertise.
“Outsourcing gives you access immediately to expertise. It may or may not be cost effective depending on the size and turnover of your organisation,” he said.
“The downside … is external expertise is not going to be as embedded in your firm's culture or even have an understanding of the client relationships. The upskilling of existing staff is great if you have the ability and facility and they have the bandwidth to do that, but it will take time.
“Effectively hiring somebody new permanently is often a gold standard of it, but it's expensive and usually only a viable option for larger firms or practices.”
For firms looking to outsource aspects of their AML/CTF program, Rippon cautioned that they would still be held ultimately responsible for any breaches.
“Simply speaking, you can outsource the mechanics, but you can't outsource the responsibility,” he said.
“The technical drafting of the AML/CTF program, training, delivery, risk assessment, facilitation and advice on reporting obligations can be outsourced, as can in fact the role of the AML/CTF compliance officer.”
Because of this, Rippon said that even firms that planned to outsource most of their AML/CTF program would need to familiarise themselves with the new rules. He also urged firms to do due diligence during the recruitment process, noting that opportunistic actors could take advantage of the surging demand for AML/CTF expertise.
“We're already seeing examples of individuals who have some financial crime knowledge rebranding themselves as AML/CTF specialists,” he said.
“The interviewing, the selection, the obtaining of verifiable references, is critical to ensure that you're selecting the right person. Where firms come to a situation where there is time pressure and a subject matter that they are not familiar with, there will be people out there who potentially will use that against them.“
While the new rules are set to bring fresh compliance burdens for accounting firms that offer designated services, Rippon reiterated that the laws had been put in place for a reason: to combat criminal activity.
The Australian Institute of Criminology (AIC) has estimated that Australia generates as much as $43.7 billion from criminal proceedings annually, although the true scale of money laundering is difficult to measure.
The Tranche 2 reforms have also brought Australia closer in line with international standards, and minimise the risk of Australia being greylisted by the Financial Action Task Force (FATF), the global money laundering and terrorism financing watchdog, at its next evaluation in 2026.
In 2024, Australia was deemed ‘non-compliant’ by FATF in four areas, including its regulation of designated service providers, which include accountants, lawyers and real estate agents. A poor evaluation by FATF in 2026 would negatively impact Australia’s reputation and could hamper trade relations.
“It's a different way of working, but actually it's about fighting the good fight. This is about doing the right thing, stopping criminals and money laundering, which at the end of the day protects families, communities, people that we may know,” Rippon said.
“And that really is a noble cause. But it does mean a way of doing things slightly differently moving forward.”
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