Tranche 2 AML/CTF Australia: What Your Business Must Do Now

Part 1 • Scope

Who Is Commonly Called Tranche 2?

Tranche 2 is a common name for the professional and property sectors brought into Australia’s AML/CTF system from 1 July 2026.

• Legal professionals who provide a covered professional service.
• Accountants who provide a covered professional service.
• Conveyancers who provide a covered conveyancing service.
• Real estate professionals who provide a covered real estate service.
• Dealers who provide a covered service involving precious metals, stones or related products.

Part 2 • Action plan

The Nine Jobs to Work Through

Use this order so the documents and day-to-day controls are built from the same view of your business.

1. Step 1

   Map your services

   List what the business actually does, who does it, where it happens and which designated-service item may apply.

2. Step 2

   Confirm enrolment

   If the business is covered and has not enrolled, deal with this now. Record the facts and advice used for any decision that enrolment is not required.

3. Step 3

   Appoint the compliance officer

   Choose a suitable person with enough authority, time and access. Newly regulated businesses had to notify AUSTRAC by the later of 29 July 2026 or 14 days after enrolment. Define who reports to whom and keep the appointment evidence.

4. Step 4

   Assess ML/TF risk

   Assess risk from customers, countries, services, delivery channels and the way the business operates. Use the result to decide which controls are needed.

5. Step 5

   Build and approve the program

   Document the governance, customer checks, reporting, staff, review and record-keeping controls. Make sure the right senior manager approves it.

6. Step 6

   Prepare customer due diligence

   Set out when to identify and verify customers, beneficial owners and people acting for them, and when enhanced checks or source-of-funds work is needed.

7. Step 7

   Train the people doing the work

   Give role-specific training before staff rely on the new process. Keep attendance, materials and follow-up records.

8. Step 8

   Set up reporting and records

   Make suspicious-matter escalation clear, protect against tipping off and keep the records needed to show compliance.

9. Step 9

   Review, test and improve

   Update the program when the business or risk changes. Arrange independent evaluation on a suitable risk-based cycle and at least every three years.

Part 3 • In practice

What Good Looks Like After Launch

• A staff member can tell when a matter or transaction enters the AML process.
• Customer checks happen before the relevant service is provided, unless a lawful exception applies.
• High-risk customers receive more checking and a clear approval decision.
• Questions and unusual activity reach the compliance officer quickly.
• The business can show why a suspicious matter was or was not reported.
• Leaders receive useful information about risk, breaches, training and remediation.
• The risk assessment and policies change when services, customers, countries or technology change.

Part 4 • Timing

Dates and Timeframes to Know

Part 5 • Choose your sector

Go to the Guide That Matches Your Work