AUSTRAC Tranche 2 obligations apply to Pubs and clubss from 1 July 2026. Select an obligation below for the full compliance guide.
The first and most urgent step under Tranche 2: register your business as a reporting entity with AUSTRAC before providing any designated services. The hard deadline is 29 July 2026. Missing it means operating outside the law from day one.
Every reporting entity must appoint an AML/CTF compliance officer at management level who is resident in Australia and a fit and proper person. You must notify AUSTRAC of your compliance officer by 29 July 2026 or 14 days after enrolling, whichever is later.
A written assessment of the money laundering and terrorism financing risks specific to your clients, services, and business model. It must be completed before you finalise your AML/CTF program and updated whenever your risk profile changes.
A board-approved, written plan that documents exactly how your business will identify, manage, and report ML/TF risks. It must cover customer due diligence, staff training, reporting obligations, and an annual review process.
Know-your-customer obligations that require you to verify the identity of clients, understand the nature of the business relationship, and monitor transactions on an ongoing basis. Enhanced CDD applies to higher-risk clients and transactions.
You must screen clients and transactions against Australian (DFAT), United Nations, and other relevant sanctions lists before providing services. Dealing with a sanctioned person or entity is a strict-liability criminal offence.
When you have reasonable grounds to suspect a matter involves proceeds of crime or ML/TF, you must file a Suspicious Matter Report (SMR) with AUSTRAC — within 24 hours for terrorism-financing matters, 3 business days for others. Tipping off a client is prohibited.
AML/CTF program documents, transaction records, CDD verification material, and SMRs must all be retained for a minimum of seven years. Records must be retrievable and producible to AUSTRAC on request.
All staff who provide or assist in providing designated services must receive AML/CTF awareness training. Training must cover how to recognise suspicious behaviour, internal reporting procedures, and the consequences of non-compliance. It must be repeated regularly.
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