Author: Viktor H
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31 March 2026: What’s Transitional, What’s Not, and Why the Distinction Will Catch People Out
The three-year grace period for initial CDD made headlines across the Australian compliance community. What didn’t make headlines is everything that has no grace period at all. On 31 March 2026 — now just weeks away — Australia’s reformed AML/CTF Act takes effect for existing reporting entities. The transitional rules announced by AUSTRAC and the Read more
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Swedbank’s Fresh AML Probe: What Happens When Remediation Doesn’t Stick
By Viktor Ha | February 2026 | AML-CAMS Blog A record SEK 4 billion fine. An internal investigation spanning 12 years. Remediation programs across four countries. A former CEO prosecuted. And on 20 February 2026 — just last week — Sweden’s Financial Supervisory Authority (Finansinspektionen, or FI) announced it will investigate whether Swedbank’s customer due Read more
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Bendigo Bank’s $50M Capital Add-On: Analyzing the APRA & AUSTRAC Joint Enforcement
By Viktor Ha | February 2026 | AML-CAMS Blog When APRA and AUSTRAC jointly announced enforcement action against Bendigo and Adelaide Bank on 17 December 2025, the headline number was AUD 50 million — an operational risk capital add-on that landed effective 1 January 2026. But the number is not the story. The story is Read more
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Deutsche Bank, Jeffrey Epstein, and the AML Failures That Led to a $150 Million Fine
In July 2020, New York regulators delivered a blunt message to one of the world’s biggest banks. Deutsche Bank AML failures had reached a point where enforcement was unavoidable. The New York State Department of Financial Services (NYDFS) imposed a $150 million civil penalty, citing years of weak controls tied most visibly to the bank’s Read more
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The “Tranche 2” Revolution: Why Real Estate Agents and Lawyers Are the New Front Line in AML
For nearly two decades, the Australian anti-money laundering landscape has been dominated by one group: the banks. If you worked in a financial institution, you lived and breathed the AML/CTF Act 2006. If you were a lawyer, accountant, or real estate agent, you were largely on the outside looking in. That era is over. Come Read more
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The Liberty Reserve Money Laundering Case: Lessons for AML and Cryptocurrency Oversight
When Arthur Budovsky’s world came crashing down in May 2013, it wasn’t just another tech entrepreneur facing legal troubles. The arrest in Madrid marked the end of what prosecutors would call the largest money laundering operation in history. Liberty Reserve, the Costa Rica-based digital currency service Budovsky had built, had become something far more sinister Read more
