Australia is moving ahead with major reforms to broaden its Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) regime. Under these reforms — commonly referred to as Tranche 2 — professions such as accountants, lawyers, conveyancers, real estate agents, trust/company service providers and others will soon be brought into the AML/CTF framework.

If you operate in one of these sectors, now is the time to prepare. Below is a clear breakdown of what’s changing, what’s required, key dates, and the consequences of non-compliance.

 

What is Tranche 2?

Tranche 2 expands the AML/CTF regime to new industries that present higher risks of money laundering or terrorism financing. These professions often act as “gatekeepers” to financial and property transactions, making them a focus for reform.

Once in effect, Tranche 2 entities will be subject to the same types of obligations already imposed on banks, financial services providers, remitters, gambling providers and other Tranche 1 entities.


Key Dates You Need to Know

These are the official implementation timeframes announced by AUSTRAC:

31 March 2026
Enrolment with AUSTRAC opens for newly regulated Tranche 2 entities.

29 July 2026
Deadline to enrol with AUSTRAC. All Tranche 2 entities must complete their enrolment by this date.

1 July 2026
AML/CTF obligations formally begin for Tranche 2 professions.
This includes customer due diligence, reporting obligations, record-keeping, and maintaining an AML/CTF program.
(Yes, obligations begin 1 July, and enrolment closes 29 July. That overlap is intentional.)

  • Obligations start: The actual rules and requirements of the new AML/CTF regime become effective on 1 July 2026.

  • Enrolment deadline: The deadline to register with AUSTRAC is 29 July 2026. This is a mandatory, separate administrative step required to be a reporting entity.

  • The gap: You are required to operate under the new rules from 1 July but have until 29 July to complete the enrolment process that officially registers your business with AUSTRAC.


Who Is Affected Under Tranche 2?

  • Accountants & Auditors

  • Lawyers & Legal Practices

  • Conveyancers

  • Real Estate Agents & Property Professionals

  • Trust & Company Service Providers

  • Potentially other “gatekeeper” professions as defined in the final rules

If your business participates in transactions involving client funds, asset transfers, trust management, property purchases or corporate structuring, you are likely to be captured.

 

Your New Obligations Under Tranche 2

1. Customer Due Diligence (KYC/CDD)
You must verify the identity of your clients and understand the nature of their activities. This includes:

  • Identity verification

  • Understanding the purpose of the transaction

  • Assessing the risk of money laundering or terrorism financing

  • Enhanced due diligence for high-risk clients

2. Reporting to AUSTRAC
You must report:

  • Suspicious Matter Reports (SMRs) — within 24 hours (or up to 3 days for less urgent matters)

  • Threshold Transaction Reports (TTRs) — for cash transactions of $10,000+

3. Record-Keeping
Tranche 2 entities must retain records for seven years, including:

  • Client identification documents

  • Transaction records

  • CDD steps

  • Training and AML/CTF program materials

4. AML/CTF Program
You must implement and maintain a written AML/CTF program that includes:

  • Risk assessments

  • Staff training

  • Internal controls

  • Ongoing monitoring

5. Appointing an AML/CTF Compliance Officer
A designated officer must oversee your compliance, reporting and staff training.

 

Penalties for Non-Compliance

Failure to comply can result in significant consequences, including:

Civil Penalties

  • Up to millions of dollars in fines depending on the breach

  • Daily penalties for ongoing non-compliance

Criminal Penalties
For severe breaches, individuals may face:

  • Criminal prosecution

  • Significant fines

  • Potential imprisonment

Other Risks

  • Loss of licence or registration (industry-specific)

  • Reputational damage

  • Increased scrutiny from AUSTRAC


How to Prepare Now

Even though obligations don’t begin until 1 July 2026, early preparation is essential:

  • Conduct an internal risk assessment

  • Review how you identify and verify clients

  • Start drafting your AML/CTF program

  • Train relevant staff

  • Set up record-keeping processes

  • Plan for AUSTRAC enrolment (opens 31 March 2026)

Early preparation means fewer surprises and lower compliance costs when the regime officially begins.

Tranche 2 represents one of the most significant regulatory shifts for Australian professional services in decades. If you work in accounting, law, conveyancing or related sectors, compliance is not optional, and preparation should start now.

If you need assistance implementing AML/CTF frameworks, reviewing current processes or preparing for AUSTRAC enrolment, we’re here to help.