Four Key Areas That Changed

1  |  Reporting Group Framework – New Opt-Out Model

This is the most important structural change. AUSTRAC has switched from an opt-in reporting group model to an opt-out model. Entities within a corporate group or control structure now automatically form a reporting group unless a reporting entity explicitly declines membership in writing. Lead entity requirements have been updated to support this change. Groups that previously needed to actively set up their reporting structure will benefit from less administrative work; entities that do not want to participate must take clear steps to opt out.

2  |  Customer Due Diligence – Technical Clarifications

Several technical CDD clarifications including: extending the timeframe to verify KYC information previously verified by another party to a real estate transaction (from 15 to 28 days); introducing deemed CDD for real estate agents where genuine attempts to conduct CDD on counterparties have been unsuccessful; and adding a requirement to monitor for prohibited hate group offences as part of unusual transaction and behaviour monitoring.

3  |  Annual Compliance Reporting – Commonwealth Framework Alignment

Compliance report periods and lodgement dates have been aligned with the Commonwealth Performance Framework as set out in the Public Governance, Performance and Accountability Act 2013. For reporting entities managing multiple regulatory reporting obligations, this alignment simplifies the annual compliance calendar and reduces the risk of conflicting lodgement deadlines.

4  |  Travel Rule – Extended Customer Exemption

The travel rule amendments extend the existing customer exemption from verifying certain payer information, including payer address, to all customers for transactions conducted before 1 July 2030. Note: virtual asset service providers must still implement the travel rule for virtual asset transfers from 1 July 2026. No exemption applies.