Tranche 2 AML/CTF reforms: the complete guide for Australian businesses
Since 1 July 2026, accountants, lawyers, conveyancers, real estate agents, trust and company service providers and dealers in precious metals and stones have had anti-money laundering obligations. Here’s who is covered, the key dates, and what you need to do, in plain English.
Last updated 28 October 2026. General information, not legal advice.
Key Tranche 2 dates
Late 2024
The AML/CTF Amendment Act 2024 passes, extending Australia’s AML/CTF regime to “Tranche 2” professions.
31 March 2026
AUSTRAC enrolment opens for newly regulated businesses, and updated obligations start for businesses that were already regulated.
1 July 2026
Tranche 2 obligations start. Businesses providing designated services must have an AML/CTF program and do customer due diligence.
29 July 2026
Deadline for businesses already providing designated services to enrol with AUSTRAC. New providers must enrol within 28 days of starting.
Who Tranche 2 covers
The law applies to the services you provide (called designated services), not your job title. If you provide any of these, you’re likely covered:
Accountants
Setting up or restructuring companies and trusts, managing client money, nominee roles, registered office services.
Lawyers
Property and business sales, managing client funds, creating and running entities, acting as or arranging nominees.
Conveyancers
Helping clients buy, sell or transfer real estate.
Real estate agents
Brokering the sale, purchase or transfer of real estate (not property management or leasing).
Jewellers & bullion dealers
Buying or selling precious metals, stones or products for $10,000 or more in cash or virtual assets.
Trust & company service providers
Creating and administering companies and trusts, nominee services, and providing a registered office or business address.
Your Tranche 2 obligations
A risk-based approach applies throughout: the depth of your checks should match the risk.
- 1
Enrol with AUSTRAC
Every business providing a designated service must be enrolled with AUSTRAC before (or within 28 days of) providing it.
- 2
Assess your ML/TF risk
A written assessment of how your services, customers, delivery channels and countries could be used for money laundering or terrorism financing, and the controls you have.
Lead AML’s guided risk assessment - 3
Have an AML/CTF program
Policies, procedures and controls that manage the risks you identified, approved by senior management and kept up to date.
Lead AML writes it from your answers - 4
Appoint a compliance officer
A suitably senior person responsible for running the program day to day.
- 5
Customer due diligence (CDD)
Identify and verify each customer before providing the service, including beneficial owners (people who own 25% or more or control the customer) and anyone acting on their behalf. Enhanced due diligence for higher-risk customers such as foreign PEPs, and ongoing due diligence throughout the relationship.
Digital ID checks, ABR/ASIC business checks and screening in the app - 6
Report to AUSTRAC
Suspicious matter reports (within 24 hours where terrorism financing is suspected, otherwise within 3 business days), threshold transaction reports for physical cash of $10,000 or more, and annual compliance reports. Never tip off a customer that a report has been or may be made.
- 7
Keep records
Keep customer identification, transaction and program records, generally for 7 years.
Every check is logged with a full audit trail - 8
Train and screen staff
Train staff on their obligations, do due diligence on staff in relevant roles, and have your program independently evaluated at least every 3 years.
Training and evaluations from our consultants
Getting compliant: where to start
- Check whether the services you provide are designated services.
- Enrol with AUSTRAC (now overdue if you were already providing designated services on 1 July 2026).
- Complete your ML/TF risk assessment.
- Adopt your AML/CTF program and appoint your compliance officer.
- Start doing CDD on new customers, and on existing customers when they ask for a new designated service or their risk changes.
- Train your team and set up record keeping.
Lead AML covers most of this in one place: the risk assessment and AML/CTF program builder, ID and business checks with screening, and consultants for training, evaluations and anything firm-specific. For the official detail, see AUSTRAC’s website.
Tranche 2 FAQs
What is Tranche 2?
Tranche 2 is the extension of Australia’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Act to professions that weren’t regulated before: lawyers, accountants, conveyancers, real estate agents, trust and company service providers, and dealers in precious metals and stones. It was made law by the AML/CTF Amendment Act 2024.
When did Tranche 2 start?
Obligations for newly regulated businesses started on 1 July 2026. AUSTRAC enrolment opened on 31 March 2026. Businesses already providing designated services had until 29 July 2026 to enrol, and new providers must enrol within 28 days of starting.
Does Tranche 2 apply to every accountant, lawyer or real estate agent?
No. It applies when you provide a “designated service”, such as helping a client buy or sell real estate or a business, managing client money, creating or restructuring companies and trusts, acting as a nominee, or providing a registered office. Tax returns and general bookkeeping on their own aren’t designated services. Use our free eligibility check to see where you stand.
What happens if we don’t comply?
AUSTRAC can take enforcement action, including infringement notices, remedial directions, enforceable undertakings and civil penalty proceedings in the Federal Court. Beyond penalties, the reputational damage to a professional practice can be serious.
Do I need to re-verify all my existing clients?
Not straight away. Customers you had before 1 July 2026 generally don’t need full CDD until they ask for a new designated service, their risk changes materially, or you need to make a suspicious matter report.
How much does Tranche 2 compliance software cost?
Lead AML plans start at $79 a month (plus GST) and include monthly credit for automated ID and business checks, plus the risk assessment and AML/CTF program builder. Every new account gets a 14-day free trial with no card needed.
Get Tranche 2 compliant in one place
- 14 days free, no card needed
- $50 of check credit to try ID and business checks
- Every Growth feature included