AML/CTF Reforms:

What Tranche 2 Businesses Need to Know Before 1 July 2026

Australia’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) regime is undergoing its most significant overhaul since 2006.

Driven by the AML/CTF Amendment Act 2024 and the updated AML/CTF Rules 2026, the reforms aim to strengthen Australia’s defences against financial crime, align with international standards, and capture newer business models such as virtual asset services.

The key change for many businesses: AML/CTF obligations are being extended to a new group of regulated entities, commonly referred to as Tranche 2 entities, from 1 July 2026.

Who is affected?

  • Real estate professionals and conveyancers
  • Dealers in precious stones and metals
  • Lawyers
  • Accountants
  • Trust and company service providers
  • Certain virtual asset service providers

These sectors are recognised internationally as potential gateways for criminals to disguise and move illicit funds. As a result, businesses in these industries are now considered “gatekeepers” against money laundering and terrorism financing, with new responsibilities to assess risk, monitor transactions, and report suspicious activity.

 

Key dates:

1 July 2026: AML/CTF obligations commence for Tranche 2 entities

29 July 2026: Deadline to notify AUSTRAC of your AML/CTF compliance officer (enrolment opened 31 March 2026)

 

What this means in practice

If your business falls within Tranche 2, you will need to:

  • Enrol with AUSTRAC as a reporting entity (by 29 July 2026)
  • Implement an AML/CTF program – risk assessments, policies, procedures, and processes tailored to your business
  • Appoint a compliance officer responsible for day-to-day management of your AML/CTF obligations
  • Train staff so they understand AML/CTF risks, internal processes, and reporting requirements
  • Carry out customer due diligence (CDD) – verifying customers on onboarding and on an ongoing basis, with enhanced checks for higher-risk clients such as politically exposed persons (PEPs) and sanctions screening
  • Report suspicious matters and threshold transactions – including international funds transfers and cash transactions over $10,000
  • Keep records for seven years covering all AML/CTF activities and compliance documentation

AUSTRAC has acknowledged this is new territory for many of these industries and has published starter kits and guidance materials to help affected businesses prepare ahead of the July 2026 commencement.

 

Next steps:

If your business operates in one of the affected sectors, now is the time to start preparing. Enrolment, program design, and compliance officer appointment all take lead time.

Please reach out to our team if you’d like assistance understanding whether these obligations apply to you and what your business needs to do to be ready.

Got questions? Email Dare Accounting.