Regulatory Focus

“We are shifting our regulatory approach from just looking at compliance, to focus on outcomes and, specifically, the harms resulting from businesses failing to manage money laundering risks.”
— Brendan Thomas, AUSTRAC CEO – 23 June 2025

 

In the rush to prepare for AML/CTF reform and the expansion of Tranche 2 obligations, the profession risks losing sight of the fundamentals. Policies, frameworks, and deadlines matter, but they are not the end goal. AUSTRAC has consistently emphasised that compliance is not about paperwork. It is about protecting the financial system from exploitation, ensuring that crime does not erode trust, and ultimately reducing harm to people and communities.

 

A Partner’s Story: From Victim to Investigator

In their early twenties, while travelling in Europe, one of Platinum AML’s partners had their credit card skimmed in Italy. The stolen funds were quickly routed through an online gambling company in Gibraltar. Stranded in a foreign city without access to money, the experience was more than an inconvenience, it was an unforgettable lesson in how financial crime, even on a small scale, can create profound personal disruption and vulnerability.

That moment proved formative. On returning to Australia, they pursued a role in financial crime investigations, driven by the desire to prevent others from experiencing similar harm. That first step evolved into a lifelong career across law enforcement, financial services, and now advisory.

‘Financial crime isn’t abstract. It’s about people whose lives are disrupted, sometimes destroyed, by organised crime.’

 

Why the ‘Why’ Matters

Stories like this remind us that financial crime is not abstract. It is not about forms, rules, or reports. It is about people. That is why the regulator is urging us to move past technical compliance and return to outcomes that harden the system against exploitation.

When Platinum AML interviews young professionals, one question is always asked: why are you interested in financial crime risk? The answer doesn’t need to be personal trauma, but it should show an appreciation of the ‘why’.

 

Back to the Fundamentals

Getting the basics right is what separates box-ticking from genuine impact. At its core, effective financial crime risk management means:

• Understanding risk — Don’t just tick a box. Learn exactly how criminals exploit gaps, misuse products, and target vulnerabilities in your designated services.
• Knowing your customer — Move beyond ID documents to build profiles that spot the difference between ordinary behaviour and suspicious activity.
• Designing effective controls — Create powerful barriers that genuinely frustrate criminal methods, rather than copying generic, ineffective templates.
• Reporting suspicious activity — Closing the loop by providing intelligence that allows law enforcement to act.

If those pillars are applied consistently, compliance follows naturally. The risk of regulatory breaches diminishes because the business is already aligned with its true purpose: reducing harm and hardening the financial system.

 

The Bigger Picture

The profession is at a crossroads, and it’s tempting to view these reforms as another technical hurdle. AUSTRAC’s new approach is a powerful reminder of the ‘why’.

Compliance is not the destination; it is the natural outcome of a purposeful effort to mitigate and manage risk. The true test is not whether your paperwork is complete, but whether your controls genuinely reduce both the likelihood and the impact of financial crime risks, and the harms they cause in the community. This sense of purpose is what separates process from true risk management.

As the reforms move forward, it is worth taking a moment to remember the initial spark, the reason so many of us entered this field. For some, it was a personal experience of being defrauded, just like our partner. For others, it was a fundamental belief in fairness and justice, or a passion for unravelling the complexities of criminal behaviour. No matter the origin, it is this sense of purpose that continues to be our most powerful guide.

 

Conclusion

Compliance is the outcome. The purpose is preventing harm and protecting communities, and we cannot afford to lose sight of that.

If you’re ready to align your compliance efforts with a purpose that matters, let’s talk. Schedule a consultation with the Platinum AML team to discuss how we can help you build a stronger, more resilient system.