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What a $15M Money Laundering Case Tells Us About the Future

By Rhiannon Davies, AML Specialist at AML Sorted


Here’s the thing. I know many law firms and real estate professionals are feeling overwhelmed by the looming Tranche 2 AML/CTF reforms. You’re being asked to get ready for something that isn’t live yet, and with limited guidance on what "ready" actually looks like.

But let’s step back for a moment.


This isn’t just regulatory box-ticking. It’s about protecting our communities from serious

harm, and there’s a very real reason why AUSTRAC is pushing for these reforms now.




A $15 Million Reminder: The Human Cost of Poor Controls


Just this week, a story broke about a Russian couple in Queensland (Alexandra Bugrova and Dmitry Rimskiy) accused of masterminding a multi-million-dollar money laundering operation.


According to the Australian Federal Police, they deposited more than $4 million in cash across 576 structured transactions, all deliberately kept under AUSTRAC’s $10,000 reporting threshold. The funds were allegedly used to purchase or rapidly repay mortgages on luxury properties.


When police raided their Hope Island home in December 2023, they found:


  • $15.6 million in seized assets

  • Seven properties

  • Half a million dollars in crypto

  • Nearly $2 million in cash, in a suitcase


This all came to light thanks to a tip-off from AUSTRAC, but here’s the uncomfortable truth. Without those red flags, it’s very possible those transactions would have continued unnoticed.



And what makes this a Tranche 2 issue is that the laundered funds were allegedly funnelled through the property sector. That includes mortgages, settlements, and dealings that may have involved legal professionals, conveyancers, or real estate agents, often without them knowing.


Tranche 2 Is About Closing the Gaps


Right now, lawyers and property professionals aren’t covered by the same AML obligations as banks and financial institutions in Australia. That’s a big gap, and one that criminals have been quick to exploit.


Tranche 2 aims to change that.


It will bring law firms, conveyancers and real estate agents under the AML/CTF regime, requiring:


  • AML Risk Assessments

  • Client due diligence checks

  • Suspicious matter reporting

  • AML policies, procedures and training


I know it feels like a lot. But I also know, from decades working with legal professionals, that when you give people the right tools and support, they’ll do the right thing.



You’re Not Expected to Be a Detective


Let me be clear. This doesn’t mean every conveyancer or solicitor needs to become an investigator. What it does mean is you need to build systems that help you spot red flags and escalate issues when needed.


It’s all about risk.


That’s why we built AML Sorted, to help firms prepare practically and confidently. We’ve translated the jargon, created easy-to-use tools, and designed live training to walk you through it step by step.


Here’s What You Can Do Now


Even though Tranche 2 isn’t here yet, you can still get ahead:

  • Review your risk exposure. What types of matters do you handle, and where are the vulnerabilities?

  • Think about your client onboarding process. Could you add simple ID checks or high-risk client flags?

  • Start your firm-wide AML Risk Assessment. It will form the backbone of your compliance program once reforms are finalised. Get in touch with us to book yours in.

  • Join one of our free live training sessions. We’re walking through all the essentials between now and September.


The Bigger Picture


Yes, these reforms mean extra work. But they also mean better protection, for your business, your clients, and your community. Criminals will always look for gaps. Tranche 2 is about closing them.


Let’s get sorted now! Feel free to drop me an email at any time: rhiannon@amlsorted.com


Rhiannon, Associate at AML Sorted

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