Does AUSTRAC have a numerical definition of "high net worth"?
No, the regime is deliberately risk-based; AUSTRAC does not prescribe wealth thresholds, transaction values or customer categories that automatically trigger Enhanced Customer Due Diligence.
No — and this isn't an oversight. The AML/CTF regime is deliberately risk-based, which means AUSTRAC doesn't prescribe wealth thresholds, transaction values or customer categories that automatically trigger Enhanced Customer Due Diligence. Reporting entities are expected to determine where the HNW line sits for their business based on their own ML/TF risk assessment, customer base and risk appetite. AUSTRAC does use the term "high-net-worth individuals" in its guidance, but only descriptively — typically when noting that secondary-source information (media coverage, published lists, commercial databases) may be more readily available for these customers when establishing source of wealth.
The more important point for practitioners is that wealth alone is not a risk indicator. A long-tenured business owner with documented earnings, transparent corporate structures and an obvious wealth narrative is likely a low-risk customer regardless of net worth. What drives ECDD obligations is the character of the wealth and the customer relationship — complex or opaque ownership structures, exposure to high-risk jurisdictions, PEP status, source-of-funds inconsistent with the known profile, or use of shell entities or layered trusts to obscure beneficial ownership. A $50M client whose wealth is plainly explained by a 30-year industry career may require less scrutiny than a $2M client with funds routed through three foreign jurisdictions.
For context, the industry conventions that do exist sit outside the AML/CTF regime: private banking and wealth management typically use thresholds around $1M AUD in investable assets (excluding the family home), with "ultra-HNW" sometimes drawn at $10M or $30M. The ATO and ASIC use different cuts for their own purposes again. These conventions can be a useful internal reference point, but they don't determine your AML/CTF obligations — your risk assessment does.
easyAML's risk profile lets you encode the wealth-related risk factors that actually matter for your firm's customer base, so the ECDD trigger fires on the right indicators rather than on a dollar figure that has no regulatory standing.