CC-101 · Lesson 1 · Why this landed on us

You are a reporting entity. So what changes?

"Reporting entity" sounds like paperwork. It is really a description of who carries the obligation — and it does not move, no matter who you hire to help.

23 September 2026 · Amanda Dunn · 5 min read

Since 1 July 2026, a great many Australian businesses that had never dealt with AUSTRAC became reporting entities. Real estate agencies, conveyancers, accounting practices and a range of other professional services.

The term gets used as though everyone already knows what it means. Most people do not, and the misunderstandings are expensive.

What the term actually describes

A reporting entity is the business that provides a service the law has singled out. Not the individual who handled the file, not the franchise brand above you, not the consultant who wrote your program. The entity.

That matters because obligations attach to it and stay there. You can buy help, software and advice. You cannot buy your way out of being the one responsible.

This is the single most common misreading: treating compliance as something you can hand to a supplier. A consultant can build your program. An agency can train your people. When AUSTRAC asks who is accountable, the answer is still you.

What decides whether you are one

It turns on the service, not on the job title. Whether a particular business is captured, and which of its activities are caught, depends on what it actually does — and that is a question for AUSTRAC’s guidance or your own adviser, not for a software company.

What is worth knowing is the shape of the test: it asks what service you provide, not what you call yourself. Two people with the same title in the same office can be in different positions, depending on what they are doing.

What changes in the working week

This is the part that surprises people. Becoming a reporting entity is not a registration you complete and forget. It is a set of things that run continuously, alongside the actual job:

You enrol with AUSTRAC and name a compliance officer — an actual person, not a role.
You assess the money-laundering and terrorism-financing risks your particular business faces, and write that down.
You build a program — the policies and processes that say how you will manage those risks.
You do customer due diligence before you provide the service, every time.
You screen for sanctions, at onboarding and on an ongoing basis.
You keep the records, review them, and report what has to be reported.

None of it is difficult to understand. All of it is a standing administrative load that most small practices were never staffed for — and that is the honest description of the problem Tranche 2 created.

Writing the policy is the easy part →Your program is judged on what you can show you did, not on what the document says you would do.

Where Curlew fits

Curlew Comply exists for the running of it. It generates the program documents from AUSTRAC’s own starter kits for your sector so the structure your assessor recognises is the structure you are working in, then carries the ongoing part: guided due diligence, automatic screening against the DFAT Consolidated List, review dates set as you complete the work, and an audit trail that builds itself.

The obligation does not shrink. The administration around it does.

The AML/CTF acronym cheatsheet →Every term you will meet, in plain English, on one printable page.