The risk assessment provides sector-specific information on ML/TF risks, and can be found at

The risk assessment counters the widely-held position that Superannuation is low ML/TF risk, establishing that:

  • AUSTRAC assesses the overall money laundering and terrorism financing (ML/TF) risk for the superannuation sector as MEDIUM.

  • This rating is based on an assessment of the criminal threat environment, the vulnerabilities within the sector, and the consequences or harms associated with the criminal threat.

  • The superannuation sector in Australia is faced with a serious and multifaceted criminal threat environment.

  • The volume and value of money moving through the sector, and the number of member accounts at the national level, make it an attractive and lucrative target for both opportunistic criminals and well-resourced organised crime groups.

  • Terrorism financing activity presents a challenge for the industry and government given the significant consequences that can occur with small amounts of funds.

  • AUSTRAC believes that significant opportunity exists for superannuation funds to leverage this assessment and to expand their suspicious matter reporting and strengthen internal controls against financial crime.

  • The information in this risk assessment relates to corporate funds, industry funds, public sector funds and retail funds. It does not specifically assess the risks posed by self-managed superannuation funds (SMSFs), although there is some reference to SMSFs in the assessment.

The AML/CTF regime is risk-based, which means that your responses to the AML/CTF obligations placed upon you should be risk-based.

A risk-based AML/CTF regime requires that you understand and address the Money Laundering and Terrorism Financing (ML/TF) risks associated with the services you offer.

You must then design, implement and maintain systems, procedures and controls that are proportionate to your ML/TF risks.

With over 50 years of expert knowledge and real world experience our AML/CTF compliance solutions will to help you navigate your legal and regulatory requirements so that your business complies with its AML/CTF obligations in the fastest and most cost-effective way.

Costos has a range of AML/CTF solutions to support your business in becoming AML/CTF compliant and maintaining compliance.