Penalty risk if you provide a designated service and are not enrolled

People search “AUSTRAC penalties Tranche 2” when a firm has been providing the service since July and wants a dollar figure for 'not being enrolled yet'. Checked against the Home Affairs page on what regulation means on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. How to enrol is the AUSTRAC enrolment guide. Whether you are a reporting entity at all is what a reporting entity is. The sector map is /tranche-2.

The risk is the unenrolled service, not a number

Firms ask for the penalty because a number feels easier than a decision. The decision is whether you provide a designated service. If you do, you are a reporting entity, and providing that service without being enrolled sits outside the regime. Consequences exist, and quoting them from memory, or from a competitor's slide, is how a wrong figure gets into a board paper.

This page will not fill that gap with a dollar amount, a penalty unit, or a 'typical fine'. It will not tell you the breach is minor because you are small, and it will not invent a grace period. If you have been providing the service and you are not enrolled, stop treating enrolment as a form you will get to, and use the enrolment guide. If you are not sure you provide the service, use the reporting-entity page before you scare yourself with a fine.

• Do not budget a fine. This page has no figure, on purpose. A made-up number is not a control.
• Do test the service. Selling, assisting a transfer, holding client money, or a nominee role are questions about the work, not about the size of a penalty.
• Do enrol if you are in. The enrol guide is the how. This page does not extend the timing.
• Do not keep providing it meanwhile. Waiting for a precise fine is not a reason to keep going unenrolled.

What people want quoted, and what to do instead

Where the penalty page stops

This page is the risk of providing a designated service while unenrolled, without a number attached. It is not the enrolment guide and it is not the test of who is a reporting entity. Those are the AUSTRAC enrolment guide and what a reporting entity is.

What the client pays

On FreeAML the firm suite is A$0. The firm emails the client a link. Verification is client-pays. On the public list a personal KYC check is A$20 and a company or trust KYB check is A$40. Use KYB when the customer is a company or a trust. A penalty is not a check fee, and enrolling does not replace the client-pays verification your program will still require. Confirm the live amounts on FreeAML pricing. FreeAML does not estimate a penalty or enrol the firm.

Frequently Asked Questions