What is Tranche 2?
Australia is extending its anti-money laundering laws to cover accountants, lawyers, real estate agents, and other professionals for the first time. Here's what you need to know.
The AML/CTF Act expansion.
Since 2006, Australia's Anti-Money Laundering and Counter-Terrorism Financing Act has required financial institutions, gambling operators, and bullion dealers to implement customer identification, transaction monitoring, and suspicious activity reporting.
Tranche 2 extends these same obligations to designated non-financial businesses and professions (DNFBPs), including accountants, lawyers, real estate agents, conveyancers, trust and company service providers, and dealers in precious metals and stones.
This brings Australia into alignment with Financial Action Task Force (FATF) recommendations and closes regulatory gaps that have been identified as enabling money laundering through professional services.
The reforms take effect on 1 July 2026, giving affected businesses approximately 18 months from the legislation passing to become fully compliant.
Key facts
Effective date
1 July 2026
Entities affected
55,000+
Regulator
AUSTRAC
Legislation
AML/CTF Act 2006
Who is affected?
Six professional sectors will be brought under the AML/CTF regime for the first time.
Accountants
CPA and CA practitioners, tax agents, BAS agents, and auditors providing financial advisory, tax planning, and audit services.
Learn moreLawyers
Solicitors and barristers involved in financial transactions, property deals, trust creation, and company formation activities.
Learn moreReal Estate Agents
Licensed agents, property managers, and developers involved in buying, selling, and leasing real property.
Learn moreConveyancers
Licensed conveyancers handling property transfers, settlement processes, and real estate transaction documentation.
Trust & Company Services
Providers creating and managing trusts, companies, and other legal entities on behalf of clients.
Precious Metals Dealers
Dealers in precious metals, stones, and jewellery above prescribed thresholds for high-value transactions.
Key milestones.
Important dates on the path to Tranche 2 compliance.
March 2024
Legislation introduced
The Anti-Money Laundering and Counter-Terrorism Financing Amendment Bill was introduced to Parliament, extending AML/CTF obligations to Tranche 2 entities.
November 2025
Rules and guidance finalised
AUSTRAC finalised the AML/CTF Rules for Tranche 2 entities, including sector-specific guidance for accountants, lawyers, and real estate agents.
Now - June 2026
Preparation period
Affected businesses should be implementing their AML/CTF programs, conducting risk assessments, training staff, and establishing compliance processes.
1 July 2026
Obligations commence
All Tranche 2 entities must have their AML/CTF programs in place and be fully operational with customer due diligence, monitoring, and reporting obligations.
Core compliance requirements.
Six key obligations that Tranche 2 entities must meet from 1 July 2026.
01
AML/CTF Program
Develop, implement, and maintain a written AML/CTF program that identifies, mitigates, and manages ML/TF risks specific to your business.
02
Customer Due Diligence
Verify the identity of clients before providing designated services. Apply enhanced due diligence for higher-risk clients and politically exposed persons.
03
Ongoing Monitoring
Continuously monitor client relationships and transactions to detect unusual or suspicious activity that may indicate money laundering or terrorism financing.
04
Suspicious Matter Reporting
Report suspicious matters to AUSTRAC within prescribed timeframes. Maintain internal processes for escalation and documentation of suspicious activity.
05
Record Keeping
Retain records of customer identification, transactions, and compliance activities for a minimum of seven years in accordance with the AML/CTF Act.
06
Staff Training
Provide regular AML/CTF awareness training to all relevant employees. Training must cover your firm's obligations, red flags, and reporting procedures.
Penalties
Non-compliance carries significant penalties.
$6.26M
Maximum individual penalty
$31.3M
Maximum corporate penalty
AUSTRAC can also impose enforceable undertakings, infringement notices, remedial directions, and in serious cases, pursue criminal prosecution. Civil penalties can be applied per contravention. Directors and officers can be held personally liable.
Tools that map to every obligation.
Purpose-built for Tranche 2 entities. Our platform maps directly to your compliance obligations.
Sanctions & PEP Screening
Screen clients against DFAT sanctions, PEP databases, and global watchlists in seconds.
Risk Assessment Builder
Generate a compliant risk assessment document with guided workflows tailored to your sector.
Audit Trail & Record Keeping
Automatic timestamped logs for every check. Export-ready for AUSTRAC inspections and audits.
Plus: AML/CTF program builder, staff training modules, compliance calendar, and AUSTRAC reporting tools.
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