AML Compliance Guide

What is Tranche 2?

Tranche 2 is the extension of Australia's Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Act to a new group of professions — including lawyers, conveyancers, accountants, real estate agents, and trust and company service providers. From 1 July 2026, these businesses must meet the same kind of AML/CTF obligations that banks and casinos have followed for years: knowing their customers, assessing risk, and reporting suspicious activity.

Last updated 13 July 2026

Sound familiar?

  • You've heard 'Tranche 2' mentioned by a colleague, industry body, or in the news, but nobody has explained what it actually means.
  • You're not sure if this is a new law, an extension of an existing one, or something that only applies to banks.
  • You don't know when it starts or whether you're already meant to be doing something about it.

Why is it called 'Tranche 2'?

Australia's AML/CTF Act has covered banks, financial services, and gambling providers since 2006 — that's now referred to as Tranche 1. Tranche 2 finally extends coverage to so-called 'gatekeeper' professions, after roughly 15 years of delay and repeated pressure from the international Financial Action Task Force (FATF) over the gap in Australia's regime.

Which professions does Tranche 2 cover?

  • Lawyers and conveyancers
  • Accountants and bookkeepers (providing certain services)
  • Real estate agents
  • Trust and company service providers
  • Dealers in precious metals and stones
  • Certain financial and lending services not already covered under Tranche 1

What's actually changing?

Covered businesses become 'reporting entities' and must enrol with AUSTRAC, assess their money laundering and terrorism financing risk, build a written AML/CTF program, verify customer identity, keep records, and report suspicious matters — obligations that didn't previously apply to these professions.

Key date

The obligations commence 1 July 2026, with enrolment required by 29 July 2026. Enrolment opened 31 March 2026.

Where this leaves you

You understand what Tranche 2 is, who it affects, and why it exists — enough to know whether you need to look further into your own obligations.

Not sure what this actually requires you to do? See what your obligations cover →

What are my AML/CTF obligations? →

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Frequently asked questions

Is Tranche 2 a new law or an amendment?
An amendment. It extends the existing Anti-Money Laundering and Counter-Terrorism Financing Act 2006, passed in 2024, to new professions rather than creating a separate act.
Does Tranche 2 apply outside Australia?
No — Tranche 2 is Australian legislation regulated by AUSTRAC. It applies to designated services provided in Australia, regardless of where a client is based.
What happens if my business ignores Tranche 2?
AUSTRAC has said it will take a proportionate, education-first approach in the first year, but it has enforcement powers including infringement notices and civil penalties for entities that don't engage at all.
Do I need a lawyer to understand my obligations?
Not necessarily — AUSTRAC publishes free starter kits and sector guidance, and plain-English guides like this one cover the basics. Legal advice is worth getting for complex or high-risk structures.

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