AML/CTF Act 2006 — Tranche 2 Reforms

Your AML/CTF
Obligations Are
Live Now.

Australian accountants, lawyers, real estate agents and conveyancers are now captured under the AML/CTF Act. The time to act is not before the deadline — it was the day the Act commenced.

Get Compliant Now Am I Captured?
⚠ Critical Deadline
1 July
2026
Program Compliance Deadline
Full AML/CTF program must be operational. Transitional period ends. AUSTRAC enforcement fully active.
29 July 2026Final date to complete AUSTRAC enrolment and notify your Compliance Officer.
31 March 2027First AML/CTF Annual Report due for the 2026 calendar year.
Who Is Captured

Does This Apply
to You?

The AML/CTF Amendment Act 2024 expanded Australia's regime to cover Designated Non-Financial Businesses and Professions (DNFBPs). If your business falls into one of these categories and provides covered services, you have legal obligations now.

⚖️
Lawyers & Law Firms
Legal practices providing services involving financial or property transactions, company formation, trust establishment, or asset management on behalf of clients.
Captured
📊
Accountants & Bookkeepers
Accounting practices providing tax advisory, financial planning, business advisory, or bookkeeping services involving client financial transactions.
Captured
🏠
Real Estate Agents
Agents involved in buying, selling, or leasing residential and commercial property on behalf of buyers or sellers.
Captured
📋
Conveyancers
Licensed conveyancers performing property settlement, title transfers, and related financial transaction services.
Captured
Your Key Obligations
1
Enrol with AUSTRAC
Register as a reporting entity on the AUSTRAC portal before 29 July 2026.
2
Appoint a Compliance Officer
Designate a responsible person and notify AUSTRAC by 29 July 2026.
3
Conduct an ML/TF Risk Assessment
Assess your money laundering and terrorism financing risk exposure across your services and client base.
4
Develop an AML/CTF Program
Create a documented program (Part A and Part B) that addresses your identified risks. Must be operational by 1 July 2026.
5
Implement KYC/CDD Procedures
Know your customer — verify client identity and conduct ongoing due diligence.
6
Report Suspicious Matters
Submit Suspicious Matter Reports (SMRs) to AUSTRAC for transactions or behaviours that raise red flags.
7
Lodge Annual AML/CTF Reports
Submit your first annual compliance report to AUSTRAC by 31 March 2027.
8
Train Your Staff
Deliver AML/CTF awareness training to all relevant staff before program commencement.
Compliance Timeline

Key Dates & Deadlines.

31 Mar 2026
✓ Passed
AML/CTF Act commenced
The AML/CTF Amendment Act 2024 took effect. Tranche 2 entities were formally captured under the regime.
31 Mar 2026
✓ Passed
AUSTRAC enrolment portal opened
Tranche 2 reporting entities became able to register and enrol with AUSTRAC.
1 Jul 2026
⚠ Urgent
⚠ AML/CTF obligations commence
Full AML/CTF program must be operational. All obligations — KYC, risk assessment, reporting, staff training — apply from this date. Transitional relief ends.
29 Jul 2026
⚠ Deadline
⚠ Enrolment & Compliance Officer notification deadline
Final date to complete AUSTRAC enrolment and notify your designated Compliance Officer. Missing this date is a direct compliance breach.
31 Mar 2027
Upcoming
First Annual AML/CTF Report due
Submit your first AML/CTF Annual Report to AUSTRAC covering the 2026 calendar year obligations.
Ongoing
Permanent
Full regime enforcement
AUSTRAC's enforcement and supervisory powers are fully operative. Civil penalties, enforceable undertakings, and criminal prosecutions available for non-compliance.
How We Help

Tranche 2 Compliance Services.

We specialise in getting Tranche 2 entities compliant — quickly, correctly, and in a way that will hold up under AUSTRAC scrutiny. All engagements are led by our CAMS-certified principal advisor.

Full Compliance Program Setup
End-to-end AML/CTF program design for Tranche 2 entities — AUSTRAC enrolment, risk assessment, program documentation, KYC procedures, and staff training. Everything you need in one engagement.
From $2,500 +GST
RapidAML Policy Document
Need a policy document today? RapidAML delivers an AUSTRAC-aligned AML/CTF policy template for just A$49. The fastest and most affordable way to get a compliance foundation in place before the deadline.
A$49 +GST — Instant
Independent Program Review
Already have a program in place? We conduct an independent evaluation against the AML/CTF Rules 2025 and deliver a clear findings report with a prioritised remediation roadmap.
From $1,800 +GST
View All Services
Common Questions

Tranche 2 FAQ.

Yes. The Tranche 2 regime applies to all entities that provide designated services — regardless of firm size. Sole practitioners, small firms, and large practices are all captured if they provide covered services to clients.
Civil penalties can reach tens of millions of dollars. AUSTRAC can also issue infringement notices, accept enforceable undertakings, seek injunctions, and refer matters for criminal prosecution. Reputational consequences for professional service firms are also significant.
No. The Act has commenced. Waiting for further industry guidance does not constitute a defence to non-compliance. You need to be making reasonable efforts to comply now, even if some guidance is still forthcoming.
Designated services are specific services listed in the AML/CTF Act that trigger reporting entity obligations. For Tranche 2 entities, these include services that involve managing client money or assets, providing financial or taxation advice, buying/selling real property, and performing conveyancing — among others.
A template can provide a useful starting point, but your AML/CTF program must be tailored to your specific business, services, clients, and risk profile. AUSTRAC expects programs to reflect genuine risk assessment — a generic document that hasn't been adapted to your business is unlikely to satisfy your obligations.
For a straightforward Tranche 2 entity such as a small accounting or law firm, we can typically complete a full program setup within 2–4 weeks. More complex businesses with multiple service lines or jurisdictions may take longer. Contact us to discuss your specific situation.

Don't wait until the deadline
is days away.

Contact us today for a confidential scoping consultation. We'll assess your obligations and outline exactly what you need to do — at no charge for the initial call.

Get Compliant Now