Australia’s sweeping anti-money laundering and counter-terrorism financing (AML/CTF) reforms are just months away from taking effect, and financial crime leaders are being urged to act with both urgency and strategic clarity.
A recent webinar featuring industry figures from Deloitte, AMP, and SymphonyAI offered a candid look at the leadership mindset and collaborative approaches needed to navigate what lies ahead.
Keep your eye on the ball
Deloitte partner and Australia and APAC financial crime lead Lisa Dobbin delivered a pointed message to leaders feeling the pressure of reform: “Keep your eye on the ball.”
Elaborating on what that means in practice, Dobbin said, “Above all else, you’ve got to continue to manage your risk. That’s the prime thing to do. But within all of that, make space for the potential innovation in the future, even if you can’t get to it now.”
She also pointed to AUSTRAC’s openness to dialogue as an underutilised resource, noting that the regulator has made clear it does not claim to have all the answers. Dobbin said, “Just be really open to engaging with AUSTRAC on how you’re thinking about navigating these challenges you’re having. They’re the first to admit they don’t have all the answers, and they’re very willing and keen and open learners of what everyone’s dealing with and how they’re grappling with both the challenges and the opportunities in this space.”
This reflects a broader philosophical shift at AUSTRAC, whose chief executive Brendan Thomas has publicly committed to moving away from a tick-box compliance model towards regulation centred on substantive risk and real-world harm. For organisations, this opens up both influence and accountability — the chance to shape how outcomes-based regulation takes form, alongside a genuine obligation to demonstrate risk management rather than minimum compliance.
Strategic clarity above all
SymphonyAI financial crime and compliance SME – APAC Craig Robertson offered a complementary perspective, urging organisations to define their objectives before committing to any particular course of action. Robertson said, “Be very clear about what are you trying to achieve. Are you trying to reduce harm? Be more efficient? Are you trying to make sure you can manage change?”
His view is that firms must be selective and deliberate during this window, acknowledging that reducing harm, improving efficiency, and managing change are all legitimate and necessary goals — but that they cannot all be pursued simultaneously with equal vigour. Robertson added that “those three things need to feature in an extended timeframe beyond 2026.”
For leaders, this demands honest internal alignment: what does the organisation most need to achieve in the near term, and how are resources and attention being directed accordingly?
A collaborative vision for the future
When panellists were asked what success looks like for Australia’s financial crime community, their answers converged around a theme of collective action over individual achievement.
AMP director of small business/personal banking – customer success and enterprise customer protection Michelle Reinisch painted a picture that extends well beyond institutional boundaries. Reinisch said, “For me, I’d like to see a sector that’s really collaborative, data smart, customer-led. I’d also love sort of real-time intelligence sharing. I think success is really about having a total mindset shift across everybody that contributes to this regime.”
She called for a shift away from “uplift” conversations towards genuine outcome-focused collaboration, including “threat hunting together” across the sector.
Real-time intelligence sharing remains technically and legally complex, but evolving frameworks — including scam prevention provisions that span banks, telecoms and digital platforms — are creating new conditions for it to happen.
From compliance to outcomes
Dobbin’s definition of success was rooted in effectiveness: moving from asking “do we have a program?” to asking “does our program work?” She said, “Success is organisations that have moved from ‘do we have a program?’ to ‘does our program work?’ That means being able to demonstrate that controls prevent or detect issues, that risk-based approaches direct resources to where they matter most, and that the organisation can show outcomes not just processes.”
This mirrors language emerging from regulators on both sides of the Pacific, including FinCEN’s 2024 proposed rule on AML programme effectiveness in the United States and AUSTRAC’s own outcomes-focused messaging in Australia.
Reinisch reinforced this point by repositioning financial crime as something far more fundamental than a regulatory obligation. Reinisch said, “For me, financial crime isn’t just a compliance issue in my world, it’s a customer promise. And for us, it’s not just about we get it right so that we don’t lose money. We get it right because we don’t want to lose customers and confidence.”
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