Submission to Attorney General on Modernising Australia’s anti-money laundering and counter-terrorism financing regime

We have made a submission in regards to Modernising Australia’s anti-money laundering and counter-terrorism financing regime.

ABIB submitted its response to the Attorney-General’s consultation on modernizing Australia’s AML/CTF laws, advocating for a distinct regulatory framework for Bitcoin-only businesses. The submission emphasized that Bitcoin, as a decentralized commodity, should be treated differently from other cryptocurrencies, which often serve as financial products. ABIB raised concerns about the disproportionate burden that broad regulatory measures, such as AFSL requirements, would place on smaller operators. It highlighted the need for cost-effective compliance solutions and recommended a tailored approach to regulation that balances innovation with crime prevention.

The submission also addressed technology-specific risks, such as custody and rehypothecation, and suggested that non-custodial models common in Bitcoin exchanges should be accounted for. ABIB urged the government to harmonize its approach with international standards, while recognizing the unique characteristics of the local Bitcoin industry. Its key recommendations included introducing tiered AML/CTF requirements, supporting low-cost compliance measures, and formally classifying Bitcoin as a commodity to foster industry growth without stifling small players.