Enforcement, exemptions and what regulators are actually likely to expect

Author, Amy Bell, CEO and Founder of AML Sorted

One of the most unhelpful myths circulating right now is that firms will either:  

- be fined immediately for minor gaps, or  

- receive broad exemptions and years of grace 

Neither of those extremes reflects the regulatory reality. 

Let’s be clear on exemptions 

There are no blanket exemptions for Tranche 2 professions. No regulator has indicated that law firms, accountants or real estate professionals will be carved out of the regime. Rumours to the contrary are wishful thinking, not policy however what may evolve is how enforcement is approached in the early stages. 

A more pragmatic supervision model 

What we are far more likely to see is a transition period where regulators focus on: 

• credible progress, not perfection 

• proportional systems, not gold‑plated frameworks 

• evidence of learning, not flawless execution 

This reflects some very real constraints:  

- AML expertise in Australia is limited  

- much of it is already absorbed by banks  

- professional services are starting from a different baseline 

That does not mean firms can sit on their hands. 

Why “wait and see” is a risky approach 

Even before legislation formally commences: 

• client onboarding risk already exists 

• trust accounts remain inherently high‑risk 

• complex ownership structures are under scrutiny 

• cross‑border work attracts attention 

  
  

Firms that can demonstrate intent, structure and momentum will be in a far stronger position than those scrambling from zero.