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When a regulator's jurisdiction grows faster than its capacity to investigate

The Comtrac Team

Jul 28, 2026

4

Min Read

Imagine a regulator wakes up one morning to find its jurisdiction has grown five-fold overnight.

That's not a thought experiment. It's what happened to AUSTRAC on 1 July 2026, when Australia's anti-money laundering and counter-terrorism financing rules extended to lawyers, accountants, real estate agents, conveyancers, and dealers in precious metals and stones. The newly regulated population will grow from around 19,000 to close to 100,000.   

On 30 June 2026, a suburban conveyancer, a two-partner accounting firm, or a real estate agency had likely never had a single dealing with AUSTRAC. By 1 July, they were reporting entities under Australia's anti-money laundering regime. 

This is what happens, sooner or later, to every regulator: a law changes, a new sector falls under its watch, and the population it's responsible for supervising grows faster, often far faster, than the team tasked with supervising it or investigating breaches. 

The investigations already on the books 

Before Tranche 2, AUSTRAC was already running investigations that show how resource-intensive this work is. 

In May 2026, AUSTRAC opened a formal enforcement investigation into Tabcorp over concerns about its ability to manage money-laundering and terrorism-financing risk, with the investigation still at an early stage and every outcome, including no further action at all, still on the table. 

Months earlier, in November 2025, Bendigo and Adelaide Bank disclosed that AUSTRAC had identified serious potential contraventions of the Act and opened its own enforcement investigation, a case that remains open. 

These are just a couple of examples, and none of these cases are quick. They involve evidence gathering, legal proceedings, and timetables measured in months, often longer. 

The resourcing picture 

The Federal Budget allocated AUSTRAC an additional funding over two years with the stated purpose is to expand AUSTRAC's regulatory, intelligence, and data capabilities and to fund guidance for newly regulated entities.  

AUSTRAC's own end-of-year update to industry describes where its attention is actually going: sector-specific guidance and starter kits, a public awareness campaign, and support to help newly regulated businesses build foundational capability such as staff training and risk awareness. AUSTRAC has also been explicit that it expects genuine progress from new entities, not perfection on day one. Those priorities are about preparing the regulated population. 

Investigation resourcing 

There's an understandable instinct to solve a five-fold increase in scope with a five-fold increase in staff. It doesn't always work in practice, and not because agencies lack the will. 

Experienced financial crime investigators take years to train. Budgets move in annual cycles. Even a generously funded hiring rounds started years ago would likely not have produced a team five or six times larger by the time obligations commence. Whatever the eventual headcount outcome, it was always going to lag the jurisdiction it needed to cover. 

That's the part most expanding regulators have to reckon with. Jurisdiction can expand quickly, and investigative capacity and capability may not be able to expand as quickly. 

A source of leverage 

Look at what actually eats the time in most regulator investigations. Most of it is spent on the mechanical work of building the case: pulling transaction records, correspondence, and account activity into a coherent evidence base, then assembling it into a brief of evidence that will hold up in court

That's exactly where AI-assisted tools change the arithmetic, without changing who makes the decisions. AI-assisted evidence mapping, structuring a sprawling document set into a coherent timeline and brief of evidence, is one of the most time-consuming parts of any investigation. Done with AI assistance, much of this can happen in a fraction of the time, turning weeks of document review into a matter of hours, while every substantive judgement about what the evidence means still sits with the investigator. 

The same applies to the brief of evidence itself. Rather than an investigator manually compiling and formatting a court-ready document from scratch once the evidence is gathered, a structured, referenced first draft can be assembled directly from the underlying material, ready for an investigator to review, refine, and sign off. The investigator remains firmly in control throughout. 

Stacked together, faster evidence mapping and faster-to-produce briefs of evidence mean a team of investigators can carry meaningfully more cases through to completion, without lowering the standard any single case is held to. 

A pattern worth watching, not a single agency's problem 

AUSTRAC's expansion is a useful case study precisely because it's so visible. But the underlying pattern shows up anywhere a regulator's jurisdiction grows faster than its team: a new integrity body standing up, a merger of regulatory functions, a legislative reform that widens who falls under an existing regime. 

The regulators that navigate this well won't be the ones waiting for a headcount number to catch up with their new remit. They'll be the ones that innovate and streamline processes and technology that help build faster briefs of evidence as infrastructure built in anticipation of jurisdictional growth, rather than assembled after the backlog becomes impossible to ignore. 

Book a demo today to see how Comtrac can help regulatory agencies with streamlining investigations and digital briefs of evidence.