This month, we examine concrete examples of AUSTRAC's evolving regulatory direction and tackle the fast-approaching deadline for SWIFT messaging changes. These developments hold valuable lessons for New Zealand financial institutions as well, particularly as regulatory approaches continue to converge across the region and the SWIFT transition affects all markets.
Story 1: AUSTRAC's Enforcement in Action
Last month, we discussed AUSTRAC's shift towards an outcomes-focused regulatory approach. This month brings real-world examples that demonstrate both sides of this evolution: enforcement action against those who fall short, and educational support for those ready to improve.
Recent enforcement closures tell a compelling story about the true cost of compliance failures. AUSTRAC has announced the closure of enforceable undertakings for NAB, PayPal, and Gold Corporation (Perth Mint): agreements that have governed these organisations for 2-3 years.
These cases illustrate a sobering reality: enforcement action means years of intensive remediation work you'd rather avoid. Companies facing undertakings typically hire additional staff, engage external consultants for oversight, and operate under heightened scrutiny from both management and AUSTRAC throughout the process.
AUSTRAC CEO's Clear Messages
AUSTRAC CEO Brendan Thomas has delivered pointed observations about these enforcement closures that every financial crime professional should heed.
On NAB's closure: "The closure of this enforceable undertaking reflects the progress NAB has made but it still doesn't give the business a clean bill of health." The message is unmistakable: even after successful remediation, AUSTRAC maintains heightened vigilance across your entire programme.
Regarding PayPal: "Any business, large or small, can work hard to turn things around, but it's better not to let issues emerge in the first place. When you slip up, it means a win for the criminals. Simply put, you may be inadvertently moving the proceeds of crime for criminals."
This reinforces AUSTRAC's core expectation: effective financial crime detection that goes beyond mere regulatory compliance. Your role extends beyond meeting obligations to actively preventing criminal exploitation of the financial system.
The Perth Mint observation was equally direct: "It shouldn't take AUSTRAC intervention and an enforceable undertaking, to get a business to focus on its money laundering risk."
The bottom line: take ownership of your compliance programme before AUSTRAC arrives at your door.
AUSTRAC has also launched civil penalty proceedings against the Mounties club, demonstrating continued enforcement activity across various sectors and entity sizes.
Story 2: AUSTRAC's Educational Push
Alongside enforcement activity, AUSTRAC is expanding educational resources, particularly for Tranche 2 reporting entities transitioning into the regime. The AUSTRAC website now contains comprehensive guidance covering legislation, sector-specific advice, national risk assessments, and suspicious activity indicators.
A series of four educational webinars specifically designed for Tranche 2 entities demonstrates AUSTRAC's commitment to supporting successful implementation. Additional resources are expected when the final rules are published in August, with core guidance following in October.
Even experienced professionals benefit from targeted training, whether to identify areas requiring attention or to reinforce confidence in current practices.
The message is clear: AUSTRAC offers both carrot and stick. Educational support is available for those proactively engaging with their obligations, whilst enforcement awaits those who fail to meet expectations.
What This Means for Australian Entities
The enforcement examples demonstrate that compliance failures carry significant operational costs: extended remediation periods, additional staffing requirements, external oversight, and persistent regulatory scrutiny. These consequences far exceed the investment required for proactive compliance management.
AUSTRAC's dual approach offers a clear choice: engage with educational resources and maintain robust programmes, or face the substantial costs of enforcement action. The broader lesson remains consistent with AUSTRAC's outcomes-focused approach: effective financial crime prevention requires more than meeting minimum standards. Success means demonstrating real-world results in detecting and disrupting criminal activity.
New Zealand's Supervisory Transition
The situation in New Zealand adds another layer of complexity with the move to a single supervisor model. Whilst the Department of Internal Affairs (DIA) has demonstrated enforcement action at various levels previously, reporting entities transitioning from the Reserve Bank of New Zealand (RBNZ) and Financial Markets Authority (FMA) to the DIA should expect differences in supervisory approach and review their compliance programmes with this uncertainty in mind.
What This Means for New Zealand Entities
This transition period creates both challenges and opportunities for New Zealand financial institutions to reassess their compliance frameworks and ensure they're positioned for success under the new supervisory structure.
Proactive engagement with the DIA's evolving approach will be crucial for maintaining effective compliance frameworks during this period of change.
Story 3: SWIFT Changes — The November Deadline Approaches
Beyond regulatory updates, practical implementation challenges loom large. November 2025 marks the final transition from legacy MT format SWIFT messages to the new MX format— a change that affects many reporting entities' international fund transfer instruction (IFTI) reporting obligations.
Taking Action on SWIFT
For organisations processing international transfers, this transition requires immediate attention. Jade ThirdEye supports automatic conversion of SWIFT messages to IFTI-E reports, helping streamline this mandatory transition (Jade ThirdEye IFTI-E Reports)
If you haven't begun preparing for the SWIFT format change, starting now is essential. Late preparation remains preferable to no preparation, but time is running short. Practical support is available, but organisations must act decisively to meet the November deadline. Take a look at our IFTI ThirdEye Explore video by clicking the button below or read our blog: From MT to MX: How Australian Banks can Navigate the SWIFT Format Change Before the November 2025 Deadline to find out more.
Stay vigilant and stay ahead. Join us next month for more insights from The FinCrime Connection, brought to you by Jade ThirdEye.
This blog is based on the August 2025 episode of The FinCrime Connection ANZ, hosted by Colin and Jing from Jade ThirdEye. Colin, AML Solution Specialist, has been with Jade ThirdEye since its inception in 2012 and works closely with clients to help them get the most from the platform. Jing, Business Development Manager, focuses on partnering with new financial institutions across Australia to enhance their AML compliance capabilities.