AML changes - impact on superannuation and other funds
26 March 2026
What do superannuation funds, retirement accounts, pension fund managers, trustees of managed investment schemes, fund managers, casinos and private credit providers have in common? From 31 March 2026, each of these entities must comply with the AML Tranche 1 reforms (March Reforms).
When you think of anti-money laundering or terrorism financing most people do not think of superannuation funds or managed investment schemes. But AUSTRAC’s 2019 Industry Specific Guidance: Superannuation Sector highlighted some of the specific risks to which the sector was exposed.
Many Tranche 1 entities like superannuation funds and managed investment schemes have assumed that the March Reforms would only require them to make small adjustments to their existing AML programs. However, this is not the case. The new laws shift the focus from compliance to the identification and management of risk and require a significant shift in the focus of existing AML Programs. Gone are the days of a template Part A and Part B AML/CTF Program. Funds must now adopt a risk-based, outcomes focused approach.
Our fact sheet, specifically tailored to the superannuation and funds industry, sets out what is changing for 31 March 2026 and provides you with tips and checklists to help guide your business. Click here to download the fact sheet.
Authors
Partner
t: +61 3 9291 2392+61 3 9291 2392
m: +61 428 641 561+61 428 641 561
o: Melbourne
Partner
t: +61 2 9260 2556+61 2 9260 2556
m: +61 412 368 176+61 412 368 176
o: Sydney
Special Counsel
t: +61 2 9260 2755+61 2 9260 2755
m: +61 460 310 444+61 460 310 444
o: Sydney
