Article: How to avoid an AML/CTF compliance disaster

A $450 million penalty. A board overhaul. And a company under constant audit. Crown Resorts shows how fast AML failures can impact a business.

In 2022 AUSTRAC commenced civil penalty proceedings against Crown for serious breaches of anti-money laundering and counter-terrorism financing laws. The Federal Court imposed the penalty in July 2023 after finding Crown had failed to adequately manage money laundering and terrorism financing risks. Since then Crown has been forced to restructure its boards, overhaul its governance frameworks and undergo ongoing compliance audits to prove its programs are sustainable.

For lawyers, accountants and real estate professionals newly captured under Tranche 2, Crown’s experience is a warning. Failures will not be treated as minor lapses. They will be treated as systemic breakdowns with reputational and financial consequences. The question is no longer whether these rules apply, but how to turn broad obligations into daily practice in busy, resource-stretched environments.

At the upcoming AML/CTF Compliance Summit 2025, three leaders will share how different sectors are navigating this shift. Marlene Sadhai of Aware Super, Kelly Dickson of Macpherson Kelley and Shaun Doyle of Ray White will explore the practical steps, cultural hurdles and low-cost wins that can help firms avoid mistakes and build frameworks that last.

Making risk-based regulation

If financial services giants struggled, it shows how challenging this will be for smaller firms. For super funds, the key hurdle has been operationalising the risk-based approach.

“In the financial services sector one of the biggest challenges was operationalising the risk-based approach,” said Marlene Sadhai. “It required a mindset shift to interpret and apply the legislation which was not as prescriptive as other legislations. This continues to be a challenge today.”

Legislation sets out principles but not blueprints. Translating that into customer due diligence, transaction monitoring and suspicious matter reporting requires both expertise and resourcing. Many firms lack both.

Sadhai notes that enforcement has been the biggest catalyst for change. “These cases shifted internal conversations from ‘compliance as cost’ to ‘compliance as protection.’ For many organisations, this led to increased board-level oversight, dedicated compliance roles, and integration of AML/CTF into broader risk management strategies.”

Changing habits in professional services

If super funds wrestled with frameworks, lawyers and accountants are grappling with culture.

“Lawyers (as we are) have spent so long not having to think about or do AML/CTF obligations in our own business,” said Kelly Dickson of Macpherson Kelley. “Changing practices, habits and thought processes for our staff ‘on the ground’, and when our lawyers and support staff just ‘want to get on with it’ and complete the transaction in front of them, needs constant focus and reminders.”

For newly regulated Tranche 2 clients, the issue is often paralysis. “A theme we have noticed is simply the overwhelm. The challenge (and the hardest part) is just to start.”

That cultural resistance, partners who want to keep things moving, staff who see compliance as red tape, remains one of the hardest barriers to overcome.

Compliance at scale in real estate

For real estate groups the challenge is not habits but scale. With hundreds of franchisees, consistency is critical.

“Our primary focus at Ray White is a smooth transition for our franchisees as they implement the new reforms,” said Shaun Doyle. “The greatest hurdle for our franchisees will be ensuring their teams are also fully compliant. To address this, we’ve launched a multi-layered communication plan for both business owners and team members. Our goal is to provide continuous updates and support, ensuring everyone in our network has the resources they need to be fully prepared by July 2026.”

Doyle believes compliance is not a distraction from growth but an enabler of it. “We’ve seen time and again across our network that this confidence in compliance is a key driver of long-term success.”

Where to start

The first steps look different in each sector, but the underlying approach is the same: begin with a clear-eyed assessment of risk and build from there.

For super funds, it starts with board-level workshops on risk appetite, baseline assessments and AML/CTF programs covering governance, reporting and escalation protocols.
For professional services firms, it begins with internal audits of client types and practice groups to pinpoint vulnerabilities.
For real estate networks, it often means checklists, playbooks and FAQs that make obligations workable for frontline teams.

As Dickson put it: “The hardest part is just to start.”

Finding low-cost wins

Even with limited resources, firms can take meaningful steps.

Sadhai points to automated compliance tools, AUSTRAC templates, industry networks and targeted training as cost-effective ways to lift capability. Dickson highlights the value of peer learning: “Talking to other businesses who have already done the AML/CTF compliance journey is so helpful.”

Doyle stresses that simplicity often works best: “Nothing beats a good checklist or playbook.”

Lessons for businesses yet to act

For firms that have not begun, the advice from all three is clear: start now, even if it is imperfect.

“Invest earlier in scalable technology, tailor risk assessments more precisely, and build frameworks that can adapt to evolving regulations and international standards,” said Sadhai.

Dickson added, “Having a basic suite of policies and procedures is better than having none at all. Get the basics for compliance in place, and refinements can follow as the business continues to learn and mature.”

Doyle’s message focuses on trust. “Businesses that focus on building a culture of compliance are often rewarded with strong performance, as this approach earns them the trust of customers and their community.”

Compliance as confidence

Crown Resorts shows what happens when compliance fails. For Tranche 2 entities, the opportunity is to learn from those mistakes before regulators force the issue.

Compliance is no longer a box-ticking exercise. It is a measure of resilience, credibility and competitive strength. Firms that act early will not only avoid penalties but also gain the trust of regulators, clients and their communities.

Tranche 2 is coming fast. Those who act now will build systems that protect their business. Those who wait risk becoming the next case study.

Join Marlene Sadhai, Kelly Dickson and Shaun Doyle and a host of other leaders at AML/CTF Compliance Summit 2025 to explore these lessons in depth and walk away with the tools and confidence to make compliance real.