Free interactive tool
What is your AML/CTF penalty exposure?
Estimate the maximum theoretical civil penalty under the AML/CTF Act for your practice, with a transparent calculation trace showing exactly how the number was derived. Four inputs, live result.
General guidance based on the AML/CTF Act 2006 s.175 and AUSTRAC’s published enforcement framing. Not legal advice. The figure is a theoretical ceiling, not a prediction of what AUSTRAC will impose.
Your practice
Four inputs. Result updates live.
Foreign-buyer settlements, international wires, offshore trust distributions, foreign-currency cash.
Precedent context
- Westpac Banking CorporationNov 2020A$1.3bn
23 million breaches; largest civil penalty in Australian corporate history.
- Crown ResortsMay 2023A$450m
Casino reporting-entity failures across multiple jurisdictions.
- Star EntertainmentOct 2024A$300m
Casino AML/CTF program and CDD failures.
- AUSTRAC v Castra Licensee Pty LtdDec 2025Pending
Smaller-entity proceeding for missed annual Compliance Reports. Confirms AUSTRAC will pursue small businesses, not just majors.
Estimated maximum theoretical exposure
$820,000
Plausible range $540,000 to $1,100,000. Band: Moderate.
How the number was calculated
1. Anchor ceiling
Per-contravention civil-penalty anchor under AML/CTF Act s.175, using the figure AUSTRAC's published enforcement guidance benchmarks against.
2. Entity-size multiplier (A$200k to A$2m)
AUSTRAC weighs harm against entity capacity. Smaller practices face a smaller realistic slice of the statutory ceiling.
3. Vertical scrutiny weight (Real estate agency)
Reflects AUSTRAC's published Tranche 2 enforcement priorities. Real estate, TCSPs and bullion dealers carry slightly higher weight.
4. Likelihood factor
Scales with customer volume (120) and cross-border transactions (8). Capped at 2.4x to avoid fake precision. Components: customers +0.20, cross-border +0.15.
5. Estimated maximum exposure (midpoint)
Plausible range $540,000 to $1,100,000. This is the theoretical ceiling, not a prediction.
This is the theoretical statutory ceiling under AML/CTF Act s.175 (with AUSTRAC’s published enforcement-anchor framing), scaled by entity size and transaction profile. It is not a prediction of what AUSTRAC will impose. General guidance only, not legal advice.
What Caltury does
Caltury runs the obligations that drop this exposure: AUSTRAC enrolment, written AML/CTF Program, customer due diligence, sanctions screening, SMR / TTR / IFTI drafting and the 7-year audit log.