Regulation changelog
A timeline of key legislative and regulatory events in Australia's AML/CTF Tranche 2 reform — from the first consultation in 2023 to the compliance deadlines in 2026 and 2027.
Government releases consultation paper
The Attorney-General's Department publishes a consultation paper proposing to extend AML/CTF obligations to lawyers, accountants, real estate agents, and other Tranche 2 professions. This followed years of FATF criticism that Australia was out of step with peer nations.
Exposure draft legislation released
The Attorney-General releases the exposure draft of the Anti-Money Laundering and Counter-Terrorism Financing Amendment Bill 2024, along with accompanying rules. Industry bodies, professional associations, and individual firms submit feedback during the 6-week consultation window.
Bill introduced to Parliament
The Anti-Money Laundering and Counter-Terrorism Financing Amendment Bill 2024 is introduced to the House of Representatives. The Bill incorporates changes responsive to industry consultation, including clearer definitions of designated services and a risk-tiered approach to compliance obligations.
Amendment Act receives Royal Assent
The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 receives Royal Assent. The Act amends the AML/CTF Act 2006 to extend obligations to Tranche 2 reporting entities. Commencement of substantive obligations is set for 1 July 2026, giving affected businesses approximately 18 months to prepare.
View source ↗AUSTRAC launches Tranche 2 education program
AUSTRAC launches a dedicated education and awareness program for Tranche 2 businesses. Resources include sector-specific fact sheets, a self-assessment tool, and a series of webinars for professional associations.
View source ↗Tranche 2 AML/CTF Rules registered
AUSTRAC registers the AML/CTF Rules (Amendment) Instrument 2025, setting out detailed requirements for AML/CTF programs, customer due diligence procedures, and reporting obligations for Tranche 2 reporting entities. The rules include simplified program templates for low-risk businesses.
Sector risk assessments published
AUSTRAC publishes money laundering/terrorism financing risk assessments for each Tranche 2 sector. The assessments rate the legal, accounting, and real estate sectors as medium-to-high risk, while smaller bookkeeping and DPMS businesses are generally rated medium risk.
AUSTRAC opens Tranche 2 enrolment portal
AUSTRAC's online enrolment portal opens for Tranche 2 reporting entities. Businesses can enrol up to nine months before the 1 July 2026 commencement date. AUSTRAC encourages early enrolment and notes that the process requires an ABN and details of all designated services provided.
6-month countdown begins
Six months remain before Tranche 2 obligations commence. AUSTRAC confirms that businesses should have their AML/CTF programs substantially drafted and their customer due diligence procedures documented by this point.
Tranche 2 obligations commence
AML/CTF obligations apply to all Tranche 2 reporting entities from this date. Businesses must have an AML/CTF program in place, conduct customer due diligence on new clients, and report suspicious matters and threshold transactions. AUSTRAC indicates it will take a proportionate approach in the first year.
AUSTRAC enrolment deadline
All Tranche 2 reporting entities must be enrolled with AUSTRAC by this date. Enrolment is a mandatory prerequisite — failure to enrol is itself a breach of the AML/CTF Act, separate from and in addition to any other compliance failures.
AML/CTF program finalisation deadline
AUSTRAC's transitional arrangements require that AML/CTF programs for all Tranche 2 reporting entities be fully documented, approved by senior management, and implemented by 31 December 2026. After this date, the full civil penalty regime applies.
Annual program reviews required
From 2027, Tranche 2 reporting entities must conduct an annual review of their AML/CTF program and update their ML/TF risk assessment whenever there is a material change to the business. AUSTRAC has indicated that proactive, documented reviews will be a key indicator of genuine compliance commitment.
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