AUSTRAC Infringement Notices Have Started: $21,840 for Not Enrolling

For the first three months of the new regime the question every Tranche 2 business asked was the same: will AUSTRAC actually fine anyone? It has started. In late September 2026 AUSTRAC confirmed it had begun issuing infringement notices to businesses that provide a designated service and never enrolled. Here is what has happened, what a notice costs, and what to do whether or not one has reached you.

What AUSTRAC has done, in order

1 July 2026. AML/CTF obligations began for real estate, legal services, accounting, conveyancing, trust and company services and dealers in precious metals and stones.
29 July 2026. The enrolment deadline passed.
August 2026. AUSTRAC began sending section 167 notices, a formal demand for information, to businesses it believed were providing designated services without having enrolled. Real Estate Business reported that at 20 August only 17,970 of roughly 45,000 real estate offices had enrolled.
Late September 2026. AUSTRAC announced it had started issuing infringement notices to businesses in real estate, accounting and jewellery that it believes failed to enrol within 28 days of first providing a designated service. CEO Brendan Thomas said about 90 per cent of the first group had since enrolled or tried to, and that AUSTRAC is actively looking for the rest and will issue more notices where needed.

So the sequence was a deadline, a formal letter asking why you missed it, and then a fine for those who still did nothing. That is the graduated approach AUSTRAC promised. It has now reached the fine.

What a notice costs

AUSTRAC set the notices at $21,840 for a company and $4,368 for an individual, which is what a sole trader is. Those are 60 and 12 penalty units at the current penalty unit value.

It is not a one-off bill. AUSTRAC's release says the penalties can accrue on a daily basis. Failing to enrol is a continuing breach, so every day a business stays un-enrolled is a fresh contravention and further notices can follow. The clock only stops when you enrol.

For comparison, enrolment itself costs nothing and takes under an hour on AUSTRAC Online.

What happens if you ignore a notice

There is a recent example, and it is worth reading because it shows the path. In September 2024 AUSTRAC issued infringement notices of $18,780 each to a group of businesses that had not lodged their annual compliance report. Two of them, Castra Licensee and Princeton Securities, did not pay. AUSTRAC took both to the Federal Court.

On 26 May 2026 the Court ordered Castra to pay a $50,000 penalty plus $15,000 in costs, and Princeton to pay $45,000 plus $5,000 in costs. Both admitted liability; Princeton's lower figure reflected that it agreed the penalty with AUSTRAC rather than contesting it. An unpaid $18,780 notice became a $65,000 bill and a published judgment with the company's name on it.

Brendan Thomas's comment at the time was blunt: businesses must respond to an infringement notice within the statutory deadline or risk significant penalties.

"I have received a notice. What now?"

Read the date. The notice carries a payment period. Everything below has to happen inside it.
Enrol today, before anything else. The notice is about not being enrolled, and that breach keeps running until you are. Enrolling does not undo the notice, but it stops the daily accrual and it is the first thing AUSTRAC will look for.
Decide what to do about the notice itself. Paying it generally brings the matter to an end for that alleged breach. If you believe you were never providing a designated service, or were not required to enrol, get legal advice before the period runs out. Whatever you decide, do not let it lapse. That is the Castra path.
Then build the rest. Enrolment is one of eight obligations. A business that was fined for not enrolling is, almost by definition, a business with no AML/CTF program and no customer checks either, and that is the next conversation AUSTRAC will want to have.

"No notice yet, and I have not enrolled"

Enrol now. Not after the next settlement, not when the accountant is back from leave. AUSTRAC has said it is looking for businesses in exactly your position, and the data it uses, ABN records, licensing registers and the businesses that did enrol, is not hard to cross-reference.

Being late and enrolled is a very different position from being found. Our enrolment guide walks through the AUSTRAC Online form, and this page covers what to do about the missed deadline itself.

"I am enrolled. Am I done?"

No. Enrolment is the easiest obligation and the only one AUSTRAC can check from its desk, which is why it is where enforcement started. The others are:

a written AML/CTF program built on a risk assessment of your own business;
customer due diligence on every customer: identity, beneficial owners, PEP and sanctions screening, a risk rating;
ongoing monitoring of those customers;
suspicious matter reports and threshold transaction reports when the triggers are met;
seven years of records;
staff training;
an annual compliance report to AUSTRAC. This is the report Castra and Princeton were fined for missing.

AUSTRAC has been consistent that a business making a genuine effort will be met with guidance first, and the first wave of fines bears that out: it went to businesses that had done nothing at all, after they were asked twice. The obvious place to look next is a business that enrolled and then stopped.

Who is in the firing line, by sector

Real estate

Every agency that sells or buys real estate for a client is captured, and the enrolment numbers say more than half had not enrolled a month after the deadline. If your office trades through a licensee company, the company is the reporting entity and the $21,840 figure is the one that applies.

Accountants and bookkeepers

Tax returns and BAS lodgements on their own are not designated services. Setting up companies or trusts, acting as a nominee director or trustee, managing client money and arranging the sale of a business are. Most practices do at least one of those. If you have decided you are out of scope, write the reasoning down, because a section 167 notice asks for exactly that.

Jewellers and bullion dealers

Dealers in precious metals and stones were named in the first round. If you buy or sell at or above the threshold in the Act, you are a reporting entity.

Enrolled, but nothing behind it yet?

CompliDesk takes a real estate agency, accounting practice or law firm from enrolled to compliant in one sitting: AML/CTF program, risk assessment, KYC and KYB checks, screening and the audit trail AUSTRAC asks for. From $39 a month, KYC checks from $3.

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Frequently Asked Questions

How much is an AUSTRAC infringement notice for not enrolling?

$21,840 for a body corporate and $4,368 for an individual, per AUSTRAC's September 2026 announcement. AUSTRAC has said the amounts can accrue daily while the business remains un-enrolled.

If I pay the notice, is that the end of it?

Paying an infringement notice generally closes the matter for that alleged contravention. It does not enrol you, and it does not cover the other obligations. Enrol immediately and get the program and customer checks in place.

Is it too late to enrol with AUSTRAC?

No. Enrolment is still open on AUSTRAC Online, is free, and takes under an hour. A business that enrols late is in a far better position than one AUSTRAC finds.

Will AUSTRAC fine me for a small mistake in my program?

AUSTRAC's stated approach is education first for businesses making a genuine effort. The first fines went to businesses that had not enrolled at all, after a deadline and a formal information request. A good-faith program with gaps is a different case from no program.

Sources: AUSTRAC, AUSTRAC begins issuing infringement notices to non-enrolled businesses (September 2026) · AUSTRAC, Federal Court imposes penalties after businesses fail to pay AUSTRAC infringement notices (May 2026) · Accountants Daily, AUSTRAC fires first fines as crackdown begins (2 October 2026) · Real Estate Business, AML crackdown begins: AUSTRAC puts real estate agencies under scrutiny (27 August 2026).

AUSTRAC Has Started Fining Businesses That Didn't Enrol: What the Notices Say and What To Do