Summary
On 31 March 2026, a range of important changes to the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Reforms came into effect for existing reporting entities. These reforms affect both initial and ongoing customer due diligence (CDD) obligations. Further, AUSTRAC has finalised the AML/CTF Transitional Rules 2026 (the transitional rules).
The transitional rules allow existing reporting entities the option to apply the Applicable Customer Identification Procedures (ACIP) in place of Initial CDD, up to a further three year period until 31 March 2029. We’re adopting these transitional rules. See the FAQs below for more information.
In relation to our products, there is no immediate action required by advisers or clients due to the reforms.
What's changing?
The reforms place increased emphasis on maintaining up to date client records, rather than relying on identification completed at a single point in time. This helps ensure financial services continue to operate securely and are not misused for unlawful activity.
We’ll adopt a phased implementation approach to these reforms over the coming months to minimise any disruptions to you and your clients. We’ll keep you informed along the way.
Keeping client details up to date
As a simple step you can take now, please encourage clients to ensure their personal details (name, residential address and contact details) held with us are correct and up to date. Maintaining current personal details supports account security, helps ensure we can stay in touch when it matters, and underpins our ongoing due diligence obligations.
How can you help your clients
You can support your clients by:
- reinforcing the importance of keeping their personal details on their account(s) current, such as name, residential address and contact details.
- encouraging your clients to register for FirstNet access or download the CFS app as easy ways to manage their personal details.
You can also update your clients’ residential address details directly via FirstNet.
Your clients can update their name by submitting the Change of details form and providing additional information, as listed on the form.
Support
If you have questions, please contact your local Business Development Manager or Adviser Services on 13 18 36, Monday to Friday between 8:30am – 6pm, Sydney time.
Frequently asked questions
The AML/CTF Reforms aim to align Australia with international standards set by the Financial Action Task Force (FATF), close regulatory gaps and combat financial crime more effectively.
There are changes to both initial and ongoing customer due diligence obligations under the new regime. These changes can affect licensees and advisers differently. As such, we recommend you review these reforms and how they relate to you.
AUSTRAC has stated the purpose of the transitional rules is to support a smooth implementation of the reforms and gives some reporting entities more time to update their systems, processes and AML/CTF programs.
Refer to AUSTRAC’s AML/CTF transitional rules update for more information. Reporting entities who adopt the transitional rules are able to delay the implementation of initial customer due diligence up until 31 March 2029.
We’ve adopted the transitional rules for initial CDD and will continue to operate under our current Applicable Customer Identification Procedures (ACIP) until we transition to the new regime. This means there is no change to our current onboarding and application process. Our goal is to comply with the regime and minimise any potential disruption.
We’re committed to clear, consistent and proactive communication, including:
- regular adviser updates, and
- advance notice of any future changes that may involve clients.
Our approach is to ensure advisers are well prepared before any client interaction is required, not after.
You can learn more about the AML/CTF reforms on the AUSTRAC website: austrac.gov.au
Adviser use only
Avanteos Investments Limited ABN 20 096 259 979, AFS Licence 245531 (AIL) is the trustee of the Colonial First State FirstChoice Superannuation Trust ABN 26 458 298 557 and issuer of FirstChoice range of super and pension products. Colonial First State Investments Limited ABN 98 002 348 352, AFSL 232468 (CFSIL) is the responsible entity and issuer of products made available under FirstChoice Investments and FirstChoice Wholesale Investments. This Information is provided by AIL and CFSIL and contains general information for the adviser only and is not to be handed to any investor. It doesn‘t take into account anyone’s individual objectives, financial situation, needs or tax circumstances. You can find the target market determinations (TMD) for our financial products at www.cfs.com.au/tmd, which include a description of who a financial product might suit. You should read the relevant Product Disclosure Statement (PDS), Investor Directed Portfolio Service Guide (IDPS Guide) and Financial Services Guide (FSG) before making any recommendations to a client. The FirstChoice PDSs and the FSG can be obtained from www.cfs.com.au or by calling us on 13 18 36.