Is Tranche 2 Law in Australia Now?

Yes. Tranche 2 of Australia’s AML/CTF reforms is now in force. As of 1 July 2026, lawyers, conveyancers, accountants, real estate agents and professionals, property developers, dealers in precious stones and precious metals, and trust and company service providers (TCSPs) are legally reporting entities under the AML/CTF Act, with core AML/CTF obligations, including AML/CTF programs, CDD, suspicious matter reporting and record keeping that have long applied to banks, casinos, and remittance providers.

This is not a future deadline to plan around. It is the current legal position for close to 100,000 businesses regulated by AUSTRAC. If your business provides a designated service in one of these sectors, your AML/CTF obligations are already in force. AUSTRAC has indicated it will prioritise enforcement against businesses that wilfully ignore their obligations or are complicit in, or wilfully blind to, money laundering activity, making early engagement with compliance essential.

What Actually Changed Today

Before 1 July 2026, many professional, real estate and precious metals/stones services were previously outside the regime. today, they carry the same core obligations as any existing reporting entity: an AML/CTF program, customer due diligence, ongoing monitoring, and reporting to AUSTRAC.

Practically, this means a real estate agency settling a property sale, a law firm handling a client’s funds in a transaction, or an accountant providing certain company formation services is now performing a ‘designated service’ under the Act. Performing that service without having enrolled with AUSTRAC and implemented a compliant program is a breach from the moment the service is provided – not from some later compliance milestone.

AUSTRAC opened enrolment for Tranche 2 entities on 31 March 2026. Businesses that started providing designated services on or after 1 July 2026 without enrolling are already out of step with their legal obligations, because the enrolment window (28 days from starting a designated service) is now running against the clock, not a future date.

Who Is Now a Reporting Entity

Tranche 2 brings five broad groups into the AML/CTF regime:

  • Legal practitioners and conveyancers providing services such as managing client money, real estate transactions, or company/trust formation.
  • Accountants providing designated services including company structuring, trust arrangements, and managing client funds or assets.
  • Real estate agents, agencies, and property developers involved in the buying and selling of real property.
  • Dealers in precious stones and precious metals above the relevant transaction thresholds.
  • Trust and company service providers (TCSPs), including those forming companies, acting as a director/secretary for a client, or providing a registered office.

If your business fits any of these descriptions and you are actively providing the relevant service, you area reporting entity now, regardless of whether you have completed enrolment or built your program yet. Delayed action doesn’t delay the obligation.

What AUSTRAC Expects From You From Today

AUSTRAC’s expectations of newly regulated entities are not aspirational; they are current legal requirements. Specifically, businesses providing designated services from 1 July 2026 must have, or be actively finalising:

  1. A board-approved, risk-based AML/CTF program setting out how the business identifies, mitigates, and manages money laundering and terrorism financing risk specific to its services and customer base
  2. An appointed AML/CTF compliance officer, with newly regulated entities required to notify AUSTRAC of that appointment by 29 July 2026
  3. Customer due diligence procedures, covering both initial verification of a customer’s identity at onboarding and ongoing monitoring of the relationship over time
  4. Transaction and suspicious matter reporting to AUSTRAC where thresholds are met or red flags are identified
  5. Seven-year record-keeping of customer identification, transaction records, and program documentation
  6. An independent evaluation of your AML/CTF program, with the first evaluation due between 30 June 2029 and 31 December 2030 for newly regulated entities, depending on the entity’s AUSTRAC account number

None of these are ‘nice to have while you finish setting up.’ Each is a live obligation attaching to every designated service performed from today onward. A business that provided a designated service on 1 July 2026 without customer due diligence in place has already created a compliance gap, not a future risk.

What Happens If You Haven’t Acted Yet

If your business hasn’t enrolled with AUSTRAC or doesn’t yet have an AML/CTF program in place, the practical position is straightforward: catch up now, not eventually. Enrol with AUSTRAC without delay if you haven’t already, appoint and notify a compliance officer ahead of the 29 July 2026 deadline, and put customer due diligence checks – identity verification, PEP and sanctions screening, adverse media checks – into your onboarding process immediately, even while your full written program is being finalised.

 

AUSTRAC’s enforcement powers apply to newly regulated entities in the same way they apply to any other reporting entity. Non-compliance carries serious civil penalty consequences under the Act, and closing a compliance gap after the fact does not undo the exposure created while it existed. The safer, faster path is to run compliant checks on new and existing customers now while the broader program is finished, rather than waiting for every piece of paperwork to be perfect before verifying a single customer.

NameScan’s pay-as-you-go PEP, sanctions, and adverse media screening, plus KYB and ID verification via API, is built for exactly this situation: newly regulated businesses that need customer due diligence running today, without a lengthy procurement or integration cycle standing between them and their current legal obligations.

Frequently Asked Questions (FAQs)

Is Tranche 2 AML/CTF law in effect in Australia?

Yes. Tranche 2 took effect on 1 July 2026. Lawyers, accountants, real estate agents and professionals, property developers, precious stone and metal dealers, and trust and company service providers are now reporting entities under the AML/CTF Act, with obligations that apply from that date, not from a future point.

Do I need to be enrolled with AUSTRAC before I can provide services?

AUSTRAC opened enrolment for Tranche 2 entities on 31 March 2026. Businesses that begin providing a designated service from 1 July 2026 must enrol within 28 days of starting that service – enrolment is not optional and the clock is already running for anyone providing designated services now.

What is the deadline to appoint a compliance officer?

Newly regulated entities must notify AUSTRAC of their appointed AML/CTF compliance officer by the later of 29 July 2026 or 14 days after enrolling with AUSTRAC. The compliance officer should already be performing the role in practice by that time, as the underlying AML/CTF obligations are already in force.

What happens if my business hasn’t set up an AML/CTF program yet?

Every designated service provided without a compliant program in place is a current compliance gap, not a future risk. The priority is to enrol with AUSTRAC immediately if you haven’t, put customer due diligence checks into place now, and finalise the full written program and independent review cycle as quickly as possible.