AML Compliance Guide

Am I covered by Tranche 2?

Whether Tranche 2 applies to you depends on the specific services you provide, not your profession or job title. AUSTRAC's test is based on 'designated services' — a defined list of activities. If you provide even one of these, you're a reporting entity for that service, regardless of how the rest of your business is set up.

Last updated 13 July 2026

Sound familiar?

  • Your profession is mentioned in Tranche 2 coverage, but you're not sure if what you personally do counts as a 'designated service'.
  • You provide a mix of services and don't know if only some of them are captured.
  • You've seen conflicting advice about whether sole practitioners or small firms are exempt.

Designated services that trigger Tranche 2 coverage

  • Lawyers and conveyancers: managing client money, real estate transactions, or creating/managing companies and trusts for a client
  • Accountants and bookkeepers: managing client money or assets, or acting for a client in a real estate or business sale/purchase
  • Real estate agents: facilitating the sale or purchase of real property
  • Trust and company service providers: acting as a formation agent, providing a registered office, or acting as a nominee shareholder/director
  • Dealers in precious metals and stones: cash transactions over the applicable threshold

What if I only do this occasionally?

There's no minimum-frequency exemption written into the designated services list — providing the service even once is generally enough to capture that service. What varies is the proportionality of your program, not whether you're captured at all.

What if my business provides several services?

You're only a reporting entity for the specific designated services you provide — not automatically for everything your business does. A firm that does conveyancing and general legal advice is only captured for the conveyancing side, but AUSTRAC still expects the whole practice's program to address how that service is managed.

Coming soon

Reporting Entity Checker

This interactive tool isn't built yet (planned component: ReportingEntityChecker). Check back soon, or read the guidance above in the meantime.

Where this leaves you

A clear yes/no on whether your business needs to comply, based on the specific designated services you provide — not just your job title.

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Frequently asked questions

I'm a sole practitioner — am I exempt?
No. There is no general exemption for sole practitioners or small businesses under Tranche 2. Size affects how detailed your program needs to be, not whether you're captured.
What if I'm unsure whether my specific service counts?
Cross-check the designated services list against what you actually do day to day, not your job title. If genuinely unclear, AUSTRAC guidance and industry bodies (Law Society, CPA Australia, REIA) publish sector-specific interpretations, or seek legal advice.
Does providing services to overseas clients change anything?
The trigger is the designated service being provided in Australia, not the client's location — servicing an overseas client through an Australian-based practice generally still counts.

This is general information, not legal advice. Always verify current requirements on the AUSTRAC website or seek professional advice for your specific situation.