I have a few points I'd like to add regarding your post:
1) Credit checks definitely do not meet AML/CTF requirements. Totally separate levels of investigation.
2) Not being labelled a credit agency does not mean an entity no longer has to do AML/CTF.
3) You're conflating the ideas of credit checks and AML/CTF. AUSTRAC definitely has room here to "come over the top" as they are looking at a separate issue to the Senate Committee.
4) From my understanding the $10,000 cap is the generic "threshold transaction" amount but the regulator is within their rights to determine an appropriate threshold amount. Just because it's below $10k doesn't mean it can't be touched by AML/CTF. **
5) Senate inquiry looked at a completely different issue. They were not tasked with looking at AML/CTF and this is not their domain.
** Relevant legislation and definition under section 5 of Anti‑Money Laundering and Counter‑Terrorism Financing Act 2006.
Found hereFor disclosure purposes: I have no skin in the game either way on this stock and honestly i doubt that there will be any enormous fallout from the audit. I just don't think you accurately illustrated the issues raised by AUSTRAC.