AML/CTF Guide
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Updates · 01 July 2026

Tranche 2 obligations commenced on 1 July 2026: what a small firm should have in place now

The second tranche of Australia's AML/CTF reforms took effect on 1 July 2026. Businesses that provide a newly designated service are now reporting entities and must enrol with AUSTRAC within 28 days of first providing it.

Source AUSTRAC — Reforms to the AML/CTF regime

What changed on the day

  • Accountants, bookkeepers, real estate agents, buyers agents, lawyers, conveyancers, trust and company service providers and dealers in precious metals and stones became reporting entities for their designated services.
  • The 28-day enrolment window started for businesses already providing those services, ending 29 July 2026.
  • Customer due diligence, reporting and record-keeping obligations apply from the first designated service provided on or after the date.

What to have in place

  1. Enrolment with AUSTRAC.
  2. An adopted AML/CTF program with a risk assessment and policies.
  3. A named compliance officer.
  4. A client identification process running for every new matter.
  5. Staff trained and the training recorded.

AUSTRAC's stated approach

AUSTRAC has said its early supervision of Tranche 2 will focus on education and helping businesses comply, with enforcement aimed at those who make no effort. Read that as a grace on tone, not on deadlines.

Questions people ask

I started providing designated services after 1 July. When do I enrol?
Within 28 days of the first service. The window runs from your start date, not from 1 July.
Tranche 2 obligations commenced on 1 July 2026: what a small firm should have in place now · AML/CTF Guide