AML/CTF Tranche 2 Reforms (2026): What Accountants, Real Estate Agents and Lawyers Need to Know
On 1 July 2026, Australia's anti-money laundering and counter-terrorism financing regulation underwent its biggest expansion in nearly two decades — the Tranche 2 reforms officially took effect. If you're an accountant, lawyer, real estate agent, conveyancer, or a trust and company service provider, your industry has been brought under AUSTRAC's oversight for the first time. For a firm like ABS Solutions — which provides accounting, tax and audit services (including audits for real estate agents, conveyancers, and SMSF trust accounts) — these reforms affect us directly, and they affect a large number of our clients too.
AML/CTF Tranche 2 Reforms (2026): What Accountants, Real Estate Agents and Lawyers Need to Know
On 1 July 2026, Australia's anti-money laundering and counter-terrorism financing regulation underwent its biggest expansion in nearly two decades — the Tranche 2 reforms officially took effect. If you're an accountant, lawyer, real estate agent, conveyancer, or a trust and company service provider, your industry has been brought under AUSTRAC's oversight for the first time. For a firm like ABS Solutions — which provides accounting, tax and audit services (including audits for real estate agents, conveyancers, and SMSF trust accounts) — these reforms affect us directly, and they affect a large number of our clients too.
Who's in scope and why now
Australia's Anti-Money Laundering and Counter-Terrorism Financing Act 2006 has, since its inception, only regulated banks, casinos and remittance providers — so-called 'Tranche 1' entities. Lawyers, accountants, real estate agents and similar professions — labelled 'gatekeeper professions' by the Financial Action Task Force (FATF) — remained largely unregulated, making Australia one of the last OECD countries without full AML/CTF coverage of these sectors. On 10 December 2024, the AML/CTF Amendment Act 2024 received royal assent, extending regulatory obligations to entities providing 'designated services' — Tranche 2 entities. The reforms are estimated to bring around 80,000–100,000 new businesses into AUSTRAC's regulatory perimeter — the largest single expansion since the regime was established in 2006.
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Australia's AML/CTF Tranche 2 Reforms Explained
A plain-English walkthrough of who's captured, what you have to do, and the deadlines that already matter.
Key dates you cannot miss
10 December 2024 — AML/CTF Amendment Act 2024 receives royal assent.
31 March 2026 — Existing Tranche 1 reporting entities must implement the new rules; AUSTRAC enrolment opens for Tranche 2 entities.
1 July 2026 — Tranche 2 obligations formally commence for newly regulated sectors.
29 July 2026 — Deadline to complete AUSTRAC enrolment if you were already providing designated services as at 1 July. This deadline has now passed — if you haven't enrolled, act immediately, because every unregistered transaction can potentially be treated as a separate contravention.
How we help you make it happen.
From compliance to optimisation — pick a topic to explore how we work with you.
Once you're a captured reporting entity, the core compliance obligations typically include AUSTRAC enrolment (the prerequisite for everything else); a written AML/CTF Program covering risk assessment, internal controls and processes; appointing an AML/CTF Compliance Officer as a 'fit and proper' nominated individual; Customer Due Diligence (CDD) — verifying client identity, understanding the purpose of transactions, and screening for politically exposed persons (PEPs) and sanctions; ongoing monitoring and risk assessment to identify unusual or suspicious transaction patterns; Suspicious Matter Reports (SMRs) reported to AUSTRAC promptly; record keeping for 7 years; and staff training so your team can apply CDD and reporting requirements. A point that's often misunderstood: the reforms regulate the 'designated service' itself, not the job title 'accountant.' Routine tax return preparation, day-to-day bookkeeping and standard advisory work don't, on their own, trigger AML/CTF obligations — but the same accountant is captured the moment they're involved in forming a company or trust, acting as a trustee, managing client funds or assets tied to a designated service, or assisting with a property transaction. Many accounting firms' work spans both categories — which is exactly why mapping out 'which specific services are designated' matters more than a blanket assumption either way.
- AUSTRAC enrolment — the prerequisite for everything else
- A written AML/CTF Program covering risk, controls and processes
- Named AML/CTF Compliance Officer
- Customer Due Diligence (CDD) — identity, purpose, PEPs and sanctions
- Ongoing monitoring and Suspicious Matter Reports (SMRs)
- 7-year record keeping and structured staff training
