Tranche 2
The next wave of AML/CTF reform is coming

Get straight to what matters with expert support to navigate tranche 2 reforms and keep your business protected.

Understanding tranche 2

What’s changing?

From 1 July 2026 Australia’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) regime will expand to include a new set of professions, including:

  • Real estate professionals
  • Accountants
  • Legal practitioners and conveyancers

In practice, that means putting risk-based AML/CTF programs in place, conducting customer due diligence, monitoring transactions, and reporting any suspicious activity to AUSTRAC.

This brings new challenges for thousands of businesses, but with our support, you’ll be ready.

Tranche 2 key dates

What it means for your business

Understanding the following AML tranche 2 obligations is the first move towards compliance.

Register your business with AUSTRAC

31 March 2026 enrolment opens

We guide you through the end-end enrolment process so you can be confident you’re fully registered by the deadline.

Build your compliance programme

A risk-based framework tailored to meet your specific needs

Get your compliance framework right with an expert risk assessment and a compliance program designed for your business needs and fully aligned with AUSTRAC standards.

Conduct customer due diligence

Identify and know your customer

Win back valuable time by letting us manage customer due diligence, while our smart software handles the routine stuff.

Report suspicious activity

Spot potential illegal activity

Our secure platform provides a full audit trail of case history, verifications, and transactions so you always have required data at your fingertips for reports and audits.

Keep detailed records

Create, store, and manage, full and accurate records

Centralised record keeping and data management systems means your customer due diligence documentation is securely kept in one place, which is easy to access, at any time, from anywhere in the world.

Train staff in AML processes

Understand obligations, risks, processes, and procedures

Turn compliance plans into confident action. We provide targeted training and guidance for compliance officers, senior managers, and staff, ensuring they have the confidence and knowledge to effectively implement your program.

Conduct employee due diligence

Screen employees for money laundering and terrorism financing risks

Fast, reliable employee screening, with identity verification and AML checks.

Compliance takes work, but we make it simple. From program design to staff training, our experts guide you through every step.

Strong compliance starts here

Expert guidance, proven processes, and technology built to keep you compliant.

Flexible options

Choose the level of expert support you need, whenever you need it. We work alongside you to help with complicated cases, or fully outsource to us and we’ll manage end-to-end compliance for you.

Expert resolution

If verification issues or PEP matches arise, we don’t send it back, we take care of it for you. From customer contact to final resolution, our experts manage every step, so once a case is closed, you can move forward with confidence.

Tailored for you

Streamline your compliance process with customised documentation tailored to your industry and business needs, including customer due diligence forms built specifically for the way your industry works.

Leading tech

Unlock secure customer onboarding with instant verification of identities using our leading AML software. Enjoy the perfect balance of speed and accuracy, ensuring a smooth experience for both you and your customers.

Strengthening your compliance strategy

As tranche 2 approaches, we’ll help you get ahead, saving time, easing the pressure, and ensuring your business stays compliant.

Use the form below to send us a message or request a consultation and we’ll get back to you within 1 working day.

Trusted by professionals across industries

More about tranche 2 reforms

What are the obligations for tranche 2 entities?

Key obligations include:

  • Registering your business with AUSTRAC
  • Creating a risk assessment and compliance programme for your business
  • Verifying new client identities and beneficial ownership structures
  • Assessing client risk and those with ongoing relationships versus one-off transactions
  • Keeping detailed records
  • Appointing a compliance officer.
  • Training staff in AML processes, and conducting employee due diligence
  • Reporting suspicious transactions and activity

Dates you don’t want to forget are:

31 March 2026 – Enrolment to AUSTRAC opens on 31 March 2026 for tranche 2 entities.

1 July 2026 – Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) obligations will apply to every single real estate agency in Australia from 1 July 2026.

This means agencies will need to have their AML processes in place, and be prepared to implement them from July 2026 in accordance with the AML/CTF Act.

Other dates to note:

October 2025 – core guidance to be released by AUSTRAC.

December 2025 – sector specific guidance to be released by AUSTRAC.

There are five key types of penalties issued for non-compliance. The penalty given will depend on the nature and/or severity of the infringement.

1. Civil Penalty Orders

Up to 20,000 penalty units for individuals

Up to 100,000 penalty units for corporations

1 penalty unit = $313, meaning fines can reach:

  • $6.26 million for individuals
  • $31.3 million for corporations

2. Enforceable Undertakings

A legally binding agreement with AUSTRAC to take corrective actions. Breaching this can lead to court enforcement.

3. Infringement Notices

Issued for breaches such as:

  • Failing to register with AUSTRAC
  • Not conducting proper KYC checks
  • Poor record-keeping

4. Remedial Directions

AUSTRAC can instruct you to take specific actions to comply

Includes submitting overdue reports or correcting compliance failures.

5. Written Notices

May require:

  • Appointment of an external auditor
  • Conducting a money laundering/terrorism financing risk assessment

An AML risk assessment is a review of your business to identify and evaluate the money laundering and terrorist financing risk to your business.

This should include tasks such as:

  • Reviewing customer profiles, their geographic locations, and transaction patterns.
  • Reviewing the products and services you offer and the risk they may pose.
  • Understanding the institutions you deal with, their nature, size and complexity.
  • Reviewing delivery channels.

Risks identified will need to be rated as to the likelihood and consequences of the risks happening to your business.

A risk assessment is fundamental to carrying out your AML obligations as it helps identify potential vulnerabilities which you should tailor your AML activity to.

A compliance program should show how you identify, mitigate and manage the risk of your products or services being used for money laundering or terrorism financing.

It must be a written document which is unique to your business and appropriate to the level of risk your business may face.

It is critical document to have, not only to comply with regulatory requirements, but it’s also your roadmap to fulfilling your obligations, and a critical tool in the ongoing battle to detect and prevent money laundering activities.

Yes. AUSTRAC states that by 1 July 2026 you must ‘train your staff on the [AML/CTF] program, internal processes, and ML/TF risks.’

You will not be able to meet your AML obligations if employees do not know what they are or how to carry them out.

Yes. The compliance officer you choose must be at management level and be able to carry out their responsibilities effectively. They will be responsible for ensuring your business complies with AML/CTF obligations.

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