AML/CTF penalties in Australia fall into civil and criminal categories, with AUSTRAC able to pursue enforceable undertakings, infringement notices and civil penalty proceedings. Penalty exposure generally turns on whether a failure was systemic and whether the entity self-reported. Confirm current penalty amounts against AUSTRAC guidance.

An AML/CTF compliance program is the written program every AUSTRAC reporting entity must have before providing a designated service. It combines an ML/TF risk assessment with AML/CTF policies, is approved by a senior manager, is followed in practice, and is reviewed, updated and independently evaluated over time.