The civil penalty bands
Maximum civil penalties under the AML/CTF Act are set by reference to the corporate and individual penalty units in force at the time. As of 2024, the maximum penalty per contravention is approximately $33 million for a body corporate and approximately $5.5 million for an individual. Multiple contraventions can be charged separately.
AUSTRAC also has a lower-tier infringement-notice regime for less serious contraventions, used to penalise systemic record-keeping or reporting failures without going to Federal Court.
Where the operational risk concentrates
Looking at how AUSTRAC has enforced against existing regulated entities (banks, casinos, remitters), the contraventions that produce the largest civil-penalty outcomes are systemic — not one-off mistakes.
- Failure to identify customers or verify identity to the program standard.
- Failure to monitor for and report suspicious matters in time.
- Failure to report threshold transactions on time.
- Inadequate AML/CTF program or program not approved by the right governance body.
- Failure to provide training or maintain records the program requires.
Tipping off is a criminal offence
If your agency lodges a Suspicious Matter Report (SMR), you must not disclose the existence or content of that report to the customer or to anyone outside your agency's reporting workflow. Tipping off carries criminal exposure — up to two years' imprisonment under the AML/CTF Act. AustracCheck's audit log marks SMR-linked customer records so internal handovers between staff stay inside the tipping-off boundary.
What lowers your enforcement exposure
AUSTRAC publicly states that an entity's enforcement posture turns on whether the program is adequate, properly governed, and documented — and whether the entity is co-operative once a problem is identified. An agency that runs its workflow inside a tool with a timestamped audit log is in a materially stronger position than one running on email threads and shared spreadsheets when an audit lands.
Tool not legal advice
AustracCheck is a workspace tool. For enforcement-risk-specific advice on your circumstances, engage a qualified Australian lawyer or compliance specialist.