AUSTRAC guidance summaries
Plain-English summaries of the key AUSTRAC guidance documents for Tranche 2 compliance, with links to the originals.
Note: These are summaries — not the guidance itself. Always read the source document before making compliance decisions. Guidance evolves as AUSTRAC publishes updates.
Getting started
AUSTRAC
·
December 2024
Tranche 2 reforms overview
Tranche 2 reforms overview
AUSTRAC's primary landing page for Tranche 2 reforms. Covers the new obligations in plain language, the timeline for commencement, and links to sector-specific resources.
Key points
- Confirms 1 July 2026 as the commencement date and 29 July 2026 for enrolment
- Lists which services are "designated services" triggering obligations
- Links to the ML/TF risk assessment self-assessment tool
- Explains the difference between a simplified and standard AML/CTF program
AUSTRAC
·
2024
What is a reporting entity?
What is a reporting entity?
Guidance on who qualifies as a reporting entity and which services trigger AML/CTF obligations. Critical starting point — if you don't provide a designated service, the Act does not apply to you.
Key points
- Designated services are listed in Table 1 of the AML/CTF Act
- Not every service a profession offers is designated — only those on the list
- Tranche 2 designated services include property transactions, company formation, and trust/asset management
- Incidental or ancillary services may not trigger the obligation
AUSTRAC
·
2025
How to enrol with AUSTRAC
How to enrol with AUSTRAC
Step-by-step guide to registering your business on the AUSTRAC Regulatory Portal. Enrolment must be completed before you start providing designated services (or by 29 July 2026 for existing businesses).
Key points
- Enrolment requires an ABN and Australian address
- You must list all designated services your business provides
- Each branch or location providing designated services must be enrolled separately
- Enrolment is free — there are no AUSTRAC registration fees for Tranche 2
AML/CTF programs
AUSTRAC
·
2025
Developing your AML/CTF program
Developing your AML/CTF program
AUSTRAC's guide to designing a compliant AML/CTF program. Explains the two-part structure (Part A: managing business risk; Part B: customer due diligence) and what each part must contain.
Key points
- Part A must set out your ML/TF risk assessment and risk-mitigation measures
- Part B must document your CDD procedures for identifying and verifying customers
- The program must be approved by senior management
- Low-risk businesses may use a simplified program structure
- The program must be reviewed and updated at least annually
AUSTRAC
·
2025
ML/TF risk assessment guide
ML/TF risk assessment guide
How to conduct a money laundering and terrorism financing risk assessment — the mandatory first step before finalising your AML/CTF program. Includes worked examples and a self-assessment questionnaire.
Key points
- Must assess risk across four dimensions: customers, services, delivery channels, and geography
- Risk ratings (low/medium/high) determine the intensity of compliance obligations
- Must be documented in writing and retained for at least 7 years after it is superseded or no longer relevant
- Must be updated whenever the business changes materially
Customer due diligence
AUSTRAC
·
2025
Customer identification and verification
Customer identification and verification
How to verify identity for individuals, companies, trusts, and other entities. Sets out what documents you must collect, what information you must verify, and when you can rely on copies rather than originals.
Key points
- Individual: name, date of birth, residential address — verified against government-issued ID
- Company: ABN/ACN, name, type of company — verified against ASIC records
- Trust: trustee details, trust deed summary, beneficial owners
- Verification must be completed before providing the designated service
- Digital verification via accredited DVS-linked providers is permitted
AUSTRAC
·
2025
Identifying beneficial owners
Identifying beneficial owners
Guidance on identifying the real humans who ultimately own or control a business or asset. This is often the most complex part of CDD, particularly for trusts, companies with complex structures, and foreign entities.
Key points
- A beneficial owner holds 25% or more of the entity, or exercises effective control
- Must look through layers of holding companies to find the ultimate beneficial owner
- For trusts: must identify all trustees, settlors (if still alive), and any beneficiaries with 25%+ interest
- If no beneficial owner can be identified, must identify and verify senior managing officials
AUSTRAC
·
2025
Ongoing customer due diligence
Ongoing customer due diligence
How to monitor ongoing relationships and update customer records. CDD is not a one-time check at onboarding — you must continue monitoring throughout the relationship.
Key points
- Must re-verify identity when there is a material change in beneficial ownership
- Must monitor transactions for consistency with the customer's profile
- High-risk customers require more frequent re-assessment
- Records must be kept for 7 years after the relationship ends
Reporting obligations
AUSTRAC
·
2025
Suspicious matter reports (SMRs)
Suspicious matter reports (SMRs)
When and how to submit an SMR. The most important reporting obligation — failure to file when you should have is a serious criminal offence, while filing a report you're not sure about is encouraged and protected by law.
Key points
- Must file within 3 business days of forming a suspicion (24 hours if terrorism financing)
- "Reasonable grounds to suspect" is a lower threshold than "believe" — suspicion is enough
- You are legally protected from any action for filing a report in good faith
- Tipping off — telling the client you've filed — is a separate criminal offence
- AUSTRAC does not confirm or deny whether it has received a specific report
AUSTRAC
·
2025
Threshold transaction reports (TTRs)
Threshold transaction reports (TTRs)
When physical currency transactions of $10,000 or more must be reported. TTRs are triggered by cash — electronic transfers do not require a TTR.
Key points
- Applies only to physical currency (notes and coins) — not EFT, cheques, or cards
- Must be filed within 10 business days of the transaction
- Structuring — deliberately splitting transactions to avoid the threshold — is a separate criminal offence
- Multiple transactions on the same day with the same customer may be aggregated
AUSTRAC
·
2025
International funds transfer instructions (IFTIs)
International funds transfer instructions (IFTIs)
Reporting requirements for cross-border transfers of money. Most relevant to remittance providers, but can also apply to lawyers and accountants who instruct international transfers on behalf of clients.
Key points
- Triggered whenever you instruct a transfer into or out of Australia on behalf of a client
- Must be filed within 10 business days
- Includes wire transfers, international remittances, and certain cryptocurrency exchanges
- Must include payer and payee details, amounts, and account information
Sector-specific guidance
AUSTRAC
·
2025
Legal practitioners and conveyancers
Legal practitioners and conveyancers
Guidance tailored to lawyers, barristers, and conveyancers. Clarifies which legal services are designated services, how legal professional privilege interacts with AML/CTF obligations, and common risk indicators in legal practice.
Key points
- Designated services include property conveyancing, company formation, managing client money, and certain trust transactions
- Pure legal advice (not involving money or asset transfers) is generally not a designated service
- Legal professional privilege does not exempt you from SMR obligations in all circumstances
- The Law Council has worked with AUSTRAC on profession-specific guidance
AUSTRAC
·
2025
Accountants and tax agents
Accountants and tax agents
Guidance for accountants, auditors, bookkeepers, and tax agents. Identifies which accounting services trigger AML/CTF obligations and how to handle clients with complex ownership structures.
Key points
- Tax return preparation alone is generally not a designated service
- Company formation, trust establishment, and managing client accounts are designated services
- Bookkeepers who handle client funds are in scope
- The Institute of Public Accountants and CPA Australia have published member guidance
AUSTRAC
·
2025
Real estate agents and property professionals
Real estate agents and property professionals
Guidance for real estate agents, buyers' agents, and property developers. The real estate sector is rated high-risk by AUSTRAC due to the large transaction values, complexity of structures used by purchasers, and historical use of Australian property for money laundering.
Key points
- Acting as agent in buying or selling real property is a designated service
- Must verify identity of both buyer and seller (not just one party)
- Must identify beneficial owner when property is being purchased by a company or trust
- Particular care required with offshore purchasers, cash deposits, and anonymous buyers
A lightweight AML platform, built exclusively for Tranche 2
Get AUSTRAC's mandates done as fast and effortless as possible.
- Built around AUSTRAC's actual requirements
- Single maintained compliance file
- No compliance expertise required
- 25 minute initial compliance setup
- Obligations calendar & reminders
- Instant data export