AUSTRAC's first full quarter regulating real estate agents, accountants, lawyers and conveyancers is over. This is what it did, what it said, and what a small firm should take from it.

1. The first fines for not enrolling

The headline. In late September AUSTRAC began issuing infringement notices, $21,840 for a company and $4,368 for an individual, to real estate, accounting and jewellery businesses that never enrolled. The notices followed a round of formal information requests in August, after which about 90 per cent of the businesses contacted enrolled or tried to. CEO Brendan Thomas said AUSTRAC is actively looking for the rest.

We have written the full story up separately, including what to do if a notice arrives: AUSTRAC has started fining businesses that didn't enrol.

2. Federal Court: what an unpaid notice becomes

On 26 May 2026 the Federal Court ordered two financial services businesses, Castra Licensee and Princeton Securities, to pay $50,000 and $45,000 respectively, plus $15,000 and $5,000 in costs. Their breach was failing to lodge a 2023 annual compliance report. The reason it reached a courtroom was that neither paid the $18,780 infringement notice AUSTRAC issued in 2024.

Why a Tranche 2 business should care: this is the mechanism the new fines sit on. An infringement notice is the cheap exit. Left unpaid, it becomes civil penalty proceedings, a larger penalty, costs, and a judgment with your name in it.

3. The big end of town: Star and Tabcorp

The Star. AUSTRAC's civil penalty case against The Star Entertainment Group has been argued and is awaiting the Federal Court's decision on the amount. AUSTRAC asked for about $400 million; Star said anything above $100 million could put it under. At the time of writing no penalty judgment has been reported. Whatever the number, it will sit beside Crown's $450 million in 2024 as the benchmark for AML enforcement in this country.

Tabcorp. On 7 May 2026 Tabcorp told the ASX that AUSTRAC had opened an enforcement investigation into its AML/CTF compliance, its second in a decade. AUSTRAC says the investigation is at an early stage and every outcome, including no further action, remains open. Tabcorp's shares fell about a quarter on the day.

Casinos and bookmakers are not your business. The questions AUSTRAC is asking them are. Does the business have a compliant program? Does it actually follow it? Does it monitor its customers? Those are the same three questions at a two-partner conveyancing practice, and the same documents answer them.

4. Where enrolment stands

The clearest public number is from real estate. At 20 August 2026, three weeks after the deadline, 17,970 of roughly 45,000 real estate offices nationally had enrolled, according to figures reported by Real Estate Business. AUSTRAC's September release suggests the information requests moved most of the businesses they reached, but it has not published an updated total.

Two cautions on that figure. Not every office is a separate reporting entity; a group with ten offices may enrol once. And the figure says nothing about whether the enrolled businesses have done anything beyond enrolling.

5. What to watch between now and the new year

What to do this month

  1. Confirm you are enrolled, and that the enrolment names the right legal entity. A notice goes to the entity that provides the service.
  2. Have a written AML/CTF program and a risk assessment you could hand over this afternoon.
  3. Check that every customer taken on since 1 July has identity, beneficial ownership, screening and a risk rating on file.
  4. Know who files your suspicious matter reports and your annual compliance report, and that they have an AUSTRAC Online login.

Four of those in one place

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Frequently Asked Questions

Has AUSTRAC fined anyone under Tranche 2 yet?
Yes. In late September 2026 AUSTRAC began issuing infringement notices to real estate, accounting and jewellery businesses that had not enrolled: $21,840 for a company and $4,368 for an individual, and the amounts can accrue daily.
What is the Star penalty likely to be?
AUSTRAC asked the Federal Court for about $400 million; The Star argued it could not survive more than $100 million. At the time of writing the Court has not handed down the penalty. Crown's 2024 penalty was $450 million.
Does AUSTRAC enforcement against casinos affect small businesses?
Not directly, but the questions are identical: is there a compliant AML/CTF program, is it followed, and are customers monitored. A small firm answers them with the same documents a casino does, at a smaller scale.

Sources: AUSTRAC, AUSTRAC begins issuing infringement notices to non-enrolled businesses · AUSTRAC, Federal Court imposes penalties after businesses fail to pay AUSTRAC infringement notices · Tabcorp, ASX announcement, 7 May 2026 · AAP, The Star faces $400m implosion over crime concerns · Real Estate Business, AML crackdown begins (27 August 2026).

Related reading: The AUSTRAC fines explained · AUSTRAC enrolment checklist · SMR and TTR reporting guide · 15 common AML compliance mistakes