Asked and answered straight
“I've missed 29 July. How much trouble am I in?”
The honest answer has three parts, and none of them is a scare. Late enrolment is itself a contravention of the AML/CTF Act — that's true the day the date passes, and no page on AUSTRAC's site says otherwise. AUSTRAC's own enrolment page still invites firms that haven't started to enrol now. And AUSTRAC's published record of enforcement actions shows no proceeding, undertaking or infringement notice against an accountant, real estate agent, conveyancer, lawyer or precious-metals dealer to date.
That last one is a fact about what has happened so far. It is not a promise about your firm, and anybody selling you one is making it up — including us, if we ever start. What it does mean is that the sensible move is the cheap one: close the obligation rather than agonise over it. Enrol (free, about 30 minutes), notify your compliance officer, and get the program built properly rather than in a panic.
The flat fact, stated once and not used as a sales lever: the AML/CTF Act's civil penalties run into the tens of millions — 100,000 penalty units for a body corporate. It's on AUSTRAC's consequences page and you should know it. It isn't why you should call us.