Biggest compliance event of 2026
AML/CTF Tranche 2 hub
On 1 July 2026, 90,000+ Australian lawyers, accountants, real estate agents, conveyancers, TCSPs and precious metals dealers became AUSTRAC reporting entities. Enrolment closes 29 July 2026 — then the real work starts: your program, your Compliance Officer, CDD and reporting. This hub is the whole path.
⏰ Enrolment closed 29 July 2026 — the obligations run from 1 July 2026 regardless
Tranche 2 of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 extends the regime from financial services to 5 new 'designated service' categories: real estate, lawyers + conveyancers, accountants + tax advisers, trust and company service providers (TCSPs), and dealers in precious metals + stones. The regime commenced 1 July 2026; AUSTRAC enrolment for day-one providers closed 29 July 2026. Missed the window? Enrol immediately — late enrolment beats non-enrolment, and your obligations have been running since 1 July either way.
If you provide any of the new designated services, you need an AML/CTF Program (Part A and Part B), an appointed AML/CTF Compliance Officer, ongoing customer due diligence (CDD) including beneficial ownership, transaction monitoring, threshold transaction reports (TTRs ≥ $10,000), international funds transfer instruction reports (IFTIs), and suspicious matter reports (SMRs) within 24 hours of forming a suspicion. Enrolled but nothing else in place? Work through the checklists and guides below in that order.
Penalties are serious: civil penalties up to $36.4M per contravention for a body corporate (100,000 penalty units at the $364 unit value from 1 July 2026), criminal offences for tipping off, and AUSTRAC actively enforcing (CBA $700M, Westpac $1.3B, SkyCity Adelaide $67M, more pending).
Free tools
Key obligations
Regulator guidance
- Guidance
AML/CTF Program — Part A + Part B requirements
Risk-based AML/CTF program structure + content expectations.
- Guidance
Customer Due Diligence (CDD)
Identifying + verifying customers + beneficial owners.
- Guidance
Suspicious Matter Reports (SMRs)
When + how to lodge SMRs with AUSTRAC.
- Guidance
Threshold Transaction Reports (TTRs)
$10,000+ cash transaction reporting via TTRs.
- Guidance
Tranche 2 reforms (1 July 2026)
Real estate, lawyers, accountants, conveyancers, TCSPs + precious metals from 1 July 2026.
Regulators
In-depth reading
- AUSTRAC enrolment for Tranche 2: step-by-step (and what to do if you missed 29 July) →
- AML/CTF Tranche 2: the complete guide for real estate, accounting, legal, conveyancing, TCSPs and precious metals →
- AML Tranche 2 for real estate agents: the complete compliance checklist →
- AUSTRAC reporting deadlines: SMR, TTR, IFTI & ACR timeframes (2026) →
- Designated services — Table 1 of section 6 AML/CTF Act →
- AML/CTF Act 2024 reforms — Tranche 2 implementation timeline →
FAQ
When does Tranche 2 actually start?
AUSTRAC enrolment opens 31 March 2026 and closes 29 July 2026 for the first wave. The full AML/CTF regime takes effect 1 July 2026 — meaning your Part A program, Compliance Officer, CDD and reporting all need to be operating from that date.
Am I a designated service provider?
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.
What is an AML/CTF Program?
Two parts: Part A is the strategic risk-based framework (risk assessment, governance, training, transaction monitoring, oversight). Part B is the customer due diligence procedure (identification, verification, beneficial ownership, ongoing monitoring). Both must be Board-approved and reviewed annually.
What does customer due diligence (CDD) actually mean?
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.
When do I file a suspicious matter report (SMR)?
Within 24 hours of forming a suspicion that a transaction may be related to a crime, tax evasion, or terrorism financing. Filing is via AUSTRAC Online. Tipping off (telling the customer you've filed) is a separate criminal offence.
What is a threshold transaction report (TTR)?
Any cash transaction of $10,000 or more (or foreign currency equivalent) — single or aggregated. Filed within 10 business days via AUSTRAC Online.
Do I need PI insurance?
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.
Will AUSTRAC actually audit small firms?
AUSTRAC has signalled phased enforcement: first 12 months focus on enrolment + Part A program + Compliance Officer appointment. Sample audits expected from 2027. But civil penalties apply from 1 July 2026 — a missed SMR is a missed SMR regardless of when AUSTRAC notices.
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