Tranche 2 explained: what changes for your business on 1 July 2026
From 1 July 2026, AML/CTF obligations extend to gatekeeper professions — lawyers, accountants, real estate agents and more. Whether you're captured depends on the designated services you provide, not your profession. Scope, enrol, and build your program early.
From 1 July 2026, Australia's anti-money-laundering regime extends to tens of thousands of businesses for the first time in two decades. Here is a plain-English breakdown of who is captured, what triggers an obligation, and the first steps to take now.
What is changing on 1 July 2026?
For most of the last twenty years, Australia's AML/CTF regime applied mainly to banks, financial institutions, remitters and casinos. The Tranche 2 reforms — introduced by the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 — close a long-standing gap by extending obligations to so-called "gatekeeper" professions.
The change brings Australia into line with the Financial Action Task Force (FATF) international standards it had been criticised for not fully meeting.
Who becomes a reporting entity?
The reforms capture several professions that, until now, sat outside the regime:
- Lawyers and conveyancers
- Accountants and bookkeepers providing designated services
- Real estate agents and property developers
- Trust and company service providers
- Dealers in precious metals and precious stones
It is the activity, not the profession, that triggers obligations. Being an accountant or lawyer does not, on its own, make you a reporting entity — you become one only when you provide a designated service with a link to Australia.
What is a "designated service"?
A designated service is a specific activity the legislation lists as carrying money-laundering or terrorism-financing risk. For the newly captured professions, common examples include:
- Managing client money, accounts or assets
- Assisting to plan or execute the sale or transfer of real estate
- Helping to create, restructure or operate a company or trust
- Acting as, or arranging, a nominee director or trustee
Mapping which of your services are "designated" is the single most important first step. Two firms in the same profession can have very different obligations depending on the services they actually provide.
The first steps to take now
- Scope your designated services.
Work through your service lines against the legislation to confirm whether — and when — you provide a designated service.
- Enrol with AUSTRAC.
Newly regulated entities must enrol within 28 days of first providing a designated service.
- Appoint a compliance officer.
A management-level officer should own the AML/CTF function.
- Build your AML/CTF program.
The written, two-part framework documenting your risk assessment (Part A) and customer due diligence (Part B).
- Stand up operational controls.
Customer verification, sanctions and PEP screening, transaction monitoring, and reporting.
The earlier you start, the cheaper compliance is. Preparing ahead of the deadline is far less expensive — and far less stressful — than scrambling to catch up after obligations have commenced.
Key takeaways
- Tranche 2 extends AML/CTF obligations to gatekeeper professions from 1 July 2026.
- It's the designated service you provide — not your profession — that captures you.
- Scope your services, enrol within 28 days, and build a two-part AML/CTF program.
- Preparing early is far cheaper than remediating after a breach.
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