AML/CTF Tranche 2 hub

It started on 1 July 2026 — your AML/CTF program, compliance officer, CDD and reporting all needed to be operating from that date. AUSTRAC enrolment opened on 31 March 2026 and is due 28 days after you first provide a designated service (29 July 2026 for businesses providing designated services from 1 July 2026). Enrolment does not 'close': later entrants enrol within 28 days of starting.

Real estate agents (buyer/seller/auction services), lawyers + conveyancers (transactions involving real estate, businesses, or trust + company structures), accountants + tax advisers (business or financial transactions on a client's behalf), TCSPs, and precious metals + stones dealers (>$10K) are all in scope. Use the Tranche 2 scope checker tool above to confirm.

Under the reformed Act, two elements: an ML/TF risk assessment, and AML/CTF policies that mitigate and manage those risks (governance, compliance officer, personnel due diligence and training, customer due diligence, transaction monitoring, reporting, record keeping). This replaced the former Part A / Part B structure. The program must be approved by your governing body or senior manager, followed in practice, and independently evaluated at least once every 3 years — for newly regulated entities the first evaluation is due between 30 June 2029 and 31 December 2030.

For each new customer (and re-verified on triggers): collect full name + date of birth + residential address; verify against an authoritative source; identify beneficial owners (any individual with ≥25% ownership or control); identify any politically exposed persons (PEPs); assess money laundering / terrorism financing risk; document the assessment.

Within 3 business days of forming a suspicion (24 hours if it relates to terrorism financing). Filing is via AUSTRAC Online. Tipping off (telling the customer you've filed) is a separate criminal offence.

Any cash transaction of $10,000 or more (or foreign currency equivalent) — single or aggregated. Filed within 10 business days via AUSTRAC Online.

AML/CTF Act doesn't require it, but professional bodies (Law Society state branches, CPA + CA ANZ, REI bodies) generally do. Tranche 2 exposure is now an insurable risk — confirm your PI policy responds to AML/CTF Act civil + criminal exposure.

AUSTRAC says it expects 'effort, not perfection' from newly regulated businesses during FY26/27, but it will take early enforcement action against businesses that fail to enrol or are complicit in money laundering. It began issuing notices to apparently unenrolled businesses on 28 August 2026. New entities are expected to be enrolled, have an AML/CTF program and compliance officer, have trained staff, and be ready to report. Civil penalty provisions have applied since 1 July 2026 — a missed SMR is a missed SMR regardless of when AUSTRAC notices. There is no routine external audit for most Tranche 2 businesses, but AUSTRAC can require one by written notice.