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Australia · AUSTRAC

AML/CTF Tranche 2: what it is and what AUSTRAC requires

Tranche 2 is the second stage of Australia's anti-money laundering and counter-terrorism financing (AML/CTF) regime. Since 1 July 2026 it has covered lawyers, accountants, conveyancers, real estate agents, trust and company service providers and dealers in precious metals and stones, whenever they provide a designated service. Those businesses must enrol with AUSTRAC within 28 days, run an AML/CTF program, check their customers, report to AUSTRAC and keep records. This page explains who it binds and what each obligation involves, and is written to be useful whether or not you ever use StackGo.

What Tranche 2 is

The AML/CTF Act, extended to the professions

Australia's AML/CTF law is the Anti-Money Laundering and Counter-Terrorism Financing Act 2006. Until 2026 it covered what is often called Tranche 1: banks and other financial services, remitters, gambling and bullion dealers. Tranche 2 is the name for extending it to a second group: certain professions and businesses that handle property, company structures and client money.

The AML/CTF Amendment Act 2024 made the change, with Royal Assent on 10 December 2024. It added two tables of designated services to section 6 of the Act: real estate services and professional services. The detail sits in the AML/CTF Rules 2025, which commenced on 31 March 2026. AUSTRAC expected the number of businesses it regulates to grow from around 19,000 to close to 100,000.

Does this apply to me

It is the service you provide, not the profession you are in

This is the single most misread part of Tranche 2. AML obligations attach to designated services. A firm can sit entirely inside a regulated profession and provide no designated service at all, and a firm can provide one without thinking of itself as an AML business. The services AUSTRAC lists for the newly regulated sectors include:

  • brokering the sale, purchase or transfer of real estate (real estate agents)
  • assisting with a transaction to buy, sell or transfer real estate (lawyers and conveyancers)
  • assisting to create or restructure a company, trust or other legal arrangement
  • receiving, holding or managing a client's money or property as part of a transaction
  • selling a shelf company, acting as or arranging a nominee director or shareholder, or providing a registered office address
  • buying or selling precious metals, stones or products for A$10,000 or more in physical currency or virtual assets

Preparing tax returns or giving tax advice is not a designated service on its own. Our guide to designated services for accountants works through the list item by item.

AML/CTF Act 2006, Tranche 2 reforms (in force 1 July 2026)

Accounting and advisory firms that provide a designated service (forming or restructuring companies and trusts, managing client money, acting as or arranging a trustee, or certain real-property and transaction work) are reporting entities under AUSTRAC. You must enrol, run customer due diligence on clients and their beneficial owners, keep records for seven years, and report suspicious matters. AML regulates the designated service you provide, not the profession.

Supervisor: AUSTRAC

Accounting & Advisory Accounting and advisory firms that provide a designated service (forming or restructuring companies and trusts, managing client money, acting as or arranging a trustee, or certain real-property and transaction work) are reporting entities under AUSTRAC. What this means for you → Legal & Law Firms Law firms that provide a designated service (managing client money, real-property transactions, forming or managing companies and trusts, or acting as or arranging a trustee) are reporting entities under AUSTRAC. What this means for you → Real Estate Real estate agents who broker the sale, purchase or transfer of real estate provide a designated service and are reporting entities under AUSTRAC. What this means for you → Conveyancing & Settlements Conveyancers who assist in the transfer of real property provide a designated service and are reporting entities under AUSTRAC. What this means for you → Trust & Company Service Providers Trust and company service providers (forming entities, acting as or arranging directors, trustees or nominees, or providing registered-office services) provide a designated service and are reporting entities under AUSTRAC. What this means for you → Precious Metals & Stones Dealers in precious metals and stones who trade above the reporting threshold provide a designated service and are reporting entities under AUSTRAC. What this means for you →
What you must do

The Tranche 2 obligations, and what each one involves

Enrolment is a one-off. The rest are ongoing, and most map to a step you have to run on real clients. The right-hand column is the mechanism, not a product claim.

  1. Enrol with AUSTRAC

    Apply to enrol in AUSTRAC Online no later than 28 days after you first provide a designated service (Act s 51B). Most Tranche 2 businesses enrol only; registration is for remitters and virtual asset service providers. Our guide to AUSTRAC enrolment covers how.

    One-off
  2. An AML/CTF program and a compliance officer

    A risk assessment of your money laundering and terrorism financing risks, and the policies that manage them, suited to the size and nature of your business. A senior manager approves it, your governing body oversees it, and an AML/CTF compliance officer at management level runs it day to day.

    Your program
  3. Customer due diligence

    Identify and verify each customer before you provide the service (Act s 28), keep it current for the whole relationship, and apply enhanced checks where the risk is high. The steps are in our customer due diligence checklist.

    Verify
  4. Beneficial ownership

    Establish who ultimately owns or controls a client entity: anyone with 25% or more, or control. A separate obligation from verifying the individual in front of you. See getting UBO right under Tranche 2.

    Intake
  5. Screening and risk

    Check clients for politically exposed person status and targeted financial sanctions, and assign a risk rating that determines how closely you monitor them.

    Screen
  6. Ongoing monitoring

    Monitor relationships for unusual activity, and update and reverify customer information at a frequency your policies set by risk.

    Monitor
  7. Report to AUSTRAC and keep records

    Suspicious matter reports within 3 business days (24 hours for terrorism financing), threshold transaction reports for A$10,000 or more in physical currency, and an annual compliance report. Keep records for 7 years, and never tip off a customer about a report.

    Ongoing
Australia, AML/CTF Act 2006 Tranche 2 at a glance
Enrol with AUSTRAC
Within 28 daysOf first providing a designated service (s 51B)
Suspicious matter report
Within 3 business daysOf forming the suspicion; 24 hours for terrorism financing (s 41)
Threshold transaction report
Within 10 business daysFor A$10,000 or more in physical currency (s 43)
Keep records
7 yearsGenerally, for CDD and transaction records
Maximum civil penalty
A$36.4 million per contravention, companyA$7.28 million for an individual. Australia’s AML/CTF Act 2006 (s 175): 100,000 and 20,000 penalty units at A$364, the rate from 1 July 2026

Sources: AUSTRAC, Enrol with us overview; AUSTRAC, Suspicious matter reports; AUSTRAC, Threshold transaction reports; AUSTRAC, Record keeping checklist; Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (ss 41, 43, 51B, 175) Reviewed

The deadlines and thresholds a Tranche 2 business works to, from the Act and AUSTRAC.
Commonly misread

Three things firms get wrong

Drawn from what practitioners actually ask, and from AUSTRAC's own guidance.

"We only screen clients receiving a designated service"

A natural reading of the Act, and it creates a practical problem. You often cannot know which clients will receive a designated service until the engagement is underway, and partial screening leaves the gap where risk actually sits. Our view is that screening broadly and monitoring by risk is the more defensible position.

"Verifying the individual is enough"

Identity verification and beneficial ownership are different obligations. Verifying the person in front of you does not tell you who ultimately owns or controls the entity, and it is the ownership chain the obligation is aimed at.

"We can complete CDD at settlement"

Initial customer due diligence comes before you provide the designated service (Act s 28). The Rules allow a delay only where it is essential to avoid interrupting the ordinary course of business and the extra risk is low, and each delay has a deadline: generally 20 business days, or for a real estate counterparty the earlier of 28 days after exchange or 3 days before settlement. If CDD cannot be completed, the service does not go ahead.

Key dates

Tranche 2 key dates

Seven dates, from the law to the first compliance report. The first period follows the financial year: 1 July 2026 to 30 June 2027, lodged between 1 July and 30 September 2027.

Tranche 2, from the law to the first compliance report

Order, not scale

  1. 10 December 2024

    The Amendment Act becomes law

    The AML/CTF Amendment Act 2024 extends the regime to Tranche 2 businesses.

  2. 29 August 2025

    The AML/CTF Rules 2025 are registered

    They set out the detail of the obligations.

  3. 31 March 2026

    Enrolment opens and the Rules commence

    Tranche 2 businesses can enrol in AUSTRAC Online.

  4. 1 July 2026

    Obligations begin

    Providing a designated service makes you a reporting entity.

  5. 29 July 2026

    Enrol within 28 days

    AUSTRAC asked businesses providing a designated service from 1 July to enrol by this date.

    A business that starts later has 28 days from its own start.

  6. 30 September 2026

    Infringement notices for not enrolling

    AUSTRAC begins issuing them to businesses it believes did not enrol on time.

  7. 1 July to 30 September 2027

    Lodge the first compliance report

    It covers 1 July 2026 to 30 June 2027.

Sources: AUSTRAC, AUSTRAC opens enrolment for new professions (31 March 2026); AUSTRAC, Enrol with us overview; AUSTRAC, AUSTRAC begins issuing infringement notices to non-enrolled businesses (30 September 2026); AUSTRAC, Annual compliance reports; Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024; Anti-Money Laundering and Counter-Terrorism Financing Rules 2025 (s 9-9) Reviewed

Tranche 2 obligations have applied since 1 July 2026. The first compliance report covers 1 July 2026 to 30 June 2027 and is lodged between 1 July and 30 September 2027.

On 10 June 2026 AUSTRAC also updated its real estate program starter kit: CDD on the counterparty can be delayed until the earlier of 28 days after exchange or 3 days before settlement (up from 15 days, under the 2026 Amendment Rules), and agencies must record the steps taken when a counterparty will not cooperate.

Latest

New on running Tranche 2

Outsourcing AML/CTF compliance: what you can hand offWhat a Tranche 2 business can hand to a provider under the AML/CTF Act, what the law keeps with the firm, and how outsourcing differs from reliance.Guide · 6 Nov 2026Choosing AML/CTF software for an accounting practiceWhat the AML/CTF Act needs your software to support, the questions to ask any vendor, and the red flags, for accounting practices under Tranche 2.Guide · 5 Nov 2026Company and trust client CDD: a checklistWhat to collect, verify, screen and record for a company, partnership, trust or SMSF client under the AML/CTF Rules 2025, one entity type at a time.Checklist · 3 Nov 2026AUSTRAC enrolment: how to enrol and whenWho must enrol with AUSTRAC, the 28-day rule, enrolment versus registration, what you need, how to enrol in AUSTRAC Online and how to keep it current.Guide · 2 Nov 2026ID checks are not onboarding: CDD for company and trust clientsWhat the AML/CTF Rules require when your client is a company, trust or partnership: the entity, its owners and controllers, who acts for it, and why.Guide · 2 Nov 2026Suspicious matter reports: when to lodge an SMR with AUSTRACWhen a suspicion means an SMR, the 24-hour and 3-business-day deadlines, what goes in the report, and what you can't tell the client afterwards.Guide · 2 Nov 2026Threshold transaction reports: the Tranche 2 cash ruleWhen A$10,000 in notes and coins triggers a threshold transaction report, when it doesn't, and what AUSTRAC's 14 October update means for your firm.Guide · 30 Oct 2026Counterparty CDD for real estate agentsWhen to check the party you don’t act for, how to rely on the conveyancer, and what to record when a buyer or seller won’t cooperate.Guide · 28 Oct 2026Real estate and Tranche 2: what AUSTRAC expectsFour months into Tranche 2, AUSTRAC is issuing infringement notices. What it expects of real estate agencies in 2026-27, and the dates ahead.Guide · 27 Oct 2026AUSTRAC’s infringement notices to unenrolled businesses: what to doAUSTRAC began issuing infringement notices to businesses that failed to enrol on 30 September 2026. What they cost, and what to do this week.Guide · 24 Oct 2026
Going deeper

Longer reads on the parts firms find hardest

The designated-services trapWhy screening every client is the more defensible reading.Getting UBO right under Tranche 2Beyond ID verification: what beneficial ownership actually requires.
Questions

Tranche 2 questions

What is Tranche 2?

Tranche 2 is the extension of Australia's AML/CTF Act 2006 to lawyers, accountants, conveyancers, real estate agents, trust and company service providers and dealers in precious metals and stones. It was made by the AML/CTF Amendment Act 2024, and the obligations began on 1 July 2026.

What is the difference between Tranche 1 and Tranche 2?

Tranche 1 is the regime that has applied since 2006, to banks and other financial services, remitters, gambling and bullion. Tranche 2 adds real estate and professional services to the designated services in section 6 of the Act. The obligations are the same kind for both: enrol, run a program, check customers, report and keep records.

Who does Tranche 2 apply to?

Any business that provides one of the newly designated services with a geographical link to Australia. It turns on the service, not the profession: an accountant who only prepares tax returns may provide no designated service, while one who helps set up a company or trust does. See designated services for accountants.

Do I enrol or register with AUSTRAC?

Most Tranche 2 businesses enrol only, in AUSTRAC Online, no later than 28 days after they first provide a designated service. Registration is an extra step for remittance and virtual asset service providers. Our guide to AUSTRAC enrolment covers how.

What happens if I don't enrol?

Since 30 September 2026 AUSTRAC has issued infringement notices to businesses it believes did not enrol on time: A$21,840 for a company and A$4,368 for an individual, which AUSTRAC says can accrue daily. Civil penalties under section 175 reach 100,000 penalty units (A$36.4 million) per contravention for a company. See AUSTRAC's infringement notices.

When is the first compliance report due?

The first reporting period for Tranche 2 businesses runs from 1 July 2026 to 30 June 2027. You lodge the report between 1 July and 30 September 2027 (Act s 47, Rules s 9-9).

What do I have to report to AUSTRAC?

A suspicious matter report within 3 business days of forming a suspicion, or 24 hours for terrorism financing; a threshold transaction report within 10 business days of a designated service involving A$10,000 or more in physical currency; and the annual compliance report. See threshold transaction reports.

Sources

Primary sources

Checked 2 November 2026.

Where StackGo fits

One way to run these obligations, not the only way

StackGo is compliance middleware. It runs the intake, verify, screen, assess and monitor steps inside the practice software your firm already uses, so the obligation is discharged where the work already happens rather than in a separate portal. Other approaches exist, including doing this manually, and this page is not an argument that you need software.

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