AML/CTF Tranche 2: What Australia's New Rules Mean for Your Business

Published June 30, 2026 • 8 min read

Australia is finishing one of the biggest expansions of its anti-money-laundering regime in two decades. The reforms bring a group of professional and real-estate services, long known as "tranche 2", into the AML/CTF net for the first time. If you're a lawyer, accountant, conveyancer, real estate agent, or deal in precious metals and stones, this affects you.

What Is "Tranche 2"?

When Australia first introduced its AML/CTF regime, it covered banks, remitters, gambling providers and similar "tranche 1" businesses. The long-anticipated "tranche 2" extends the same style of obligations to additional designated services, commonly summarised as:

• Lawyers and conveyancers (for certain services)
• Accountants and other professional service providers
• Real estate agents
• Dealers in precious metals and precious stones
• Trust and company service providers

From 1 July 2026, these sectors are expected to begin operating under AML/CTF obligations. Many entities will need to enrol with AUSTRAC and have a compliant program in place.

What You'll Actually Need to Do

The obligations are principles-based, which means they scale to the size and risk of your business. The core building blocks are:

1. An AML/CTF Program (Part A and Part B)

A documented program is the backbone. Part A is your risk-management framework: how you identify, assess, and mitigate money-laundering and terrorism-financing (ML/TF) risk. Part B covers your customer due diligence procedures.

2. ML/TF Risk Assessment

Before you write the program, you assess your risk across customers, services, delivery channels, and jurisdictions. The assessment drives everything else; a low-risk sole practice and a high-volume agency should not have identical controls.

3. Customer Due Diligence (CDD)

Know who your customer is. That means collecting and verifying identity, understanding beneficial ownership for entities, and applying enhanced due diligence where risk is higher. Ongoing CDD keeps that picture current.

4. Reporting

• SMRs (Suspicious Matter Reports) when you form a relevant suspicion.
• TTRs (Threshold Transaction Reports) for cash transactions at or above the prescribed threshold.
• IFTIs (International Funds Transfer Instructions) where applicable.

5. Governance, Training and Record-Keeping

Appoint an AML/CTF Compliance Officer, train your staff, keep records for the required period, and have your program independently reviewed on a reasonable cycle.

The Practical Challenge for Small Firms

For a major bank, this is business as usual. For a three-partner law firm or a suburban real estate office, building a risk assessment, writing a two-part program, and standing up CDD and reporting from scratch is daunting; and the cost of getting it wrong is real.

A Sensible Way to Prepare

1. Confirm whether you provide a designated service. Not every activity is captured; scope it precisely.
2. Do the risk assessment first. It sizes everything that follows.
3. Draft a proportionate Part A and Part B. Match the controls to your actual risk.
4. Set up CDD workflows your team will actually use. Friction is the enemy of compliance.
5. Enrol with AUSTRAC and stay current. Track deadlines and keep your program reviewed.

Software That Does the Heavy Lifting

This is exactly the gap our AML/CTF Compliance tool was built to close. It guides tranche-2 entities through an ML/TF risk assessment, helps you build a Part A and Part B program, structures your customer due diligence, and tracks your SMR/TTR/IFTI obligations; turning a pile of legislation into a clear, repeatable workflow you can keep on top of.