On 9 February 2026, AUSTRAC released an Exposure Draft of the Anti-Money Laundering and Counter-Terrorism Financing (2025 Rules) Amendment Rules 2026 and invited feedback from industry.

MinterEllison made a submission supporting the policy objectives underpinning the AML/CTF reforms and the reporting group framework for the administrative efficiencies it may provide. However, we raised several concerns with the proposed amendments to the reporting group rules.

Most importantly, the proposed amendments would effectively mandate that if a group of related entities wished to form a reporting group, they could only do so if all members of that corporate group agreed to form a single reporting group. This would capture foreign entities in the group that may have no connection to Australia. The proposed amendments therefore eliminate the ability to establish multiple reporting groups within a single corporate structure. These changes impose practical and operational burdens inconsistent with the stated objective of facilitating flexible and efficient compliance arrangements. 

MinterEllison's full submission outlines in further detail our:

• recommendation that AUSTRAC reconsider the introduction of the opt-out mechanism for the formation of a reporting group.  We instead request AUSTRAC provide express clarification that multiple business groups can exist within a corporate structure, consistent with the statutory language and policy intent, thereby providing corporate groups with the flexibility to tailor reporting group structures to their operational and governance realities;
• submission that if AUSTRAC proceeds with the proposed opt-out mechanism, foreign entities within a business group that are not reporting entities and have no connection to Australia should be excluded from the reporting group unless the relevant foreign entity elects to opt in; and
• support for the proposed amendment to Rule 6-32 to allow completion of Initial Customer Due Diligence within 28 days (rather than 15 days) after a reporting entity commences providing the designated service in Item 1 of Table 5, together with a recommendation to extend the same approach to Item 3 of Table 6 designated services provided in connection with the same transaction, and to Item 2 of Table 5 designated services, where reporting entities face the same practical challenges.