In June 2022, we provided feedback to AUSTRAC on draft guidance, and we’re pleased to see our recommendations included, particularly those supporting people recently in prison and transgender, intersex, and gender-diverse individuals. This change aims to ease access to financial services, where identification barriers often restrict entry. We recommend adding prison case workers and reintegration officers as acceptable referees, especially given that many Victorian prisons lack financial counselling services. Additionally, we urge AUSTRAC to address individual “debanking” in its guidance, as disadvantaged individuals, not just businesses, sometimes face account closures despite posing no financial crime risk.