Tranche 2, and what it actually requires of you
From 1 July 2026, providing a designated service makes you a reporting entity under the AML/CTF Act 2006. This page explains what that means, who it binds, and what each obligation involves. It is written to be useful whether or not you ever use StackGo.
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.
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
Five obligations, and what each one involves
Enrolment is a one-off. The rest are ongoing, and each maps to a step you have to run on real clients. The right-hand column is the mechanism, not a product claim.
- Enrol with AUSTRAC
A one-off registration as a reporting entity, due once you begin providing a designated service.
One-off - Customer due diligence
Identify and verify every client before you act, and keep that identification current as the relationship continues.
- Beneficial ownership
Establish who ultimately owns or controls a client entity. A separate obligation from verifying the individual in front of you.
- Screening and risk
Check clients against sanctions, PEP and adverse-media sources, and assign a risk rating that determines how closely you monitor them.
- Ongoing monitoring and reporting
Monitor relationships for unusual activity, keep records for seven years, and report suspicious matters to AUSTRAC.
Three things firms get wrong
Drawn from what practitioners actually ask, and from AUSTRAC's own guidance updates.
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. Screening broadly and monitoring by risk is the more defensible position.
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.
CDD must be complete before or at the time the designated service is provided. Where it cannot be completed in time, the transaction does not proceed. AUSTRAC's real estate guidance names this as the most common failure.
What has already happened
- 10 June 2026AUSTRAC 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.
- 1 July 2026Tranche 2 obligations commence. Providing a designated service from this date makes you a reporting entity.
Longer reads on the parts firms find hardest
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.
Ready to make onboarding minutes, not hours?
Start free and run your first check today, or book a demo and we will walk you through it.