AML/CTF Act 2024 reforms — Tranche 2 implementation timeline

Royal assent and structure

The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 (Cth) received Royal Assent on 10 December 2024. This legislation introduces significant reforms to Australia’s anti-money laundering and counter-terrorism financing (AML/CTF) framework. For a comprehensive overview, see AML Tranche 2 complete guide.

The amendments commenced in stages across 2025 and 2026. Both key dates have now passed: the reformed obligations applied to existing reporting entities from 31 March 2026, and Tranche 2 obligations commenced on 1 July 2026.

The Act expands the AML/CTF regime to include a range of previously exempt professions and businesses. These Tranche 2 entities include lawyers, conveyancers, accountants, real estate professionals, dealers in precious metals and stones, and trust and company service providers. It also modernises obligations for existing reporting entities, such as digital currency exchange providers and remittance providers.

Existing entities — 31 March 2026

Since 31 March 2026, existing reporting entities have been subject to the reformed AML/CTF program framework: an ML/TF risk assessment plus AML/CTF policies, replacing the former Part A / Part B structure. Their AML/CTF programs must be updated to reflect the new requirements outlined in the AML/CTF Act 2024. AUSTRAC enrolment 31 March 2026 walkthrough provides further information.

Key updates to programs include strengthened beneficial ownership identification and updated PEP screening rules. Reporting entities should review AUSTRAC’s published transitional guidance to understand the specific changes and their obligations.

AUSTRAC enrolment for newly regulated entities also opened on 31 March 2026. AUSTRAC enrolment walkthrough offers a guide to the enrolment process.

Tranche 2 entities — 1 July 2026

Since 1 July 2026, Tranche 2 reporting entities have been required to comply with the AML/CTF Act in respect of newly designated services. This group includes lawyers, conveyancers, accountants, real estate professionals, dealers in precious metals and stones, and trust and company service providers (TCSPs). These obligations are in force now. AML Tranche 2 lawyers and conveyancers checklist ; AML Tranche 2 accountants checklist ; AML Tranche 2 real estate checklist

The obligations for Tranche 2 entities include enrolment with AUSTRAC (due 28 days after first providing a designated service — 29 July 2026 for services provided from 1 July 2026), maintaining an AML/CTF program (ML/TF risk assessment plus AML/CTF policies), designating an AML/CTF compliance officer, conducting customer due diligence, lodging reports (SMRs within 3 business days of forming a suspicion, or 24 hours for terrorism financing), and maintaining records. These requirements are designed to mitigate the risk of money laundering and terrorism financing.

AUSTRAC has said it expects "effort, not perfection" during FY26/27, but that it will take early enforcement action against businesses that fail to enrol. On 28 August 2026 it began issuing information notices to apparently unenrolled real estate agents, accountants, lawyers and jewellers.

What firms should be doing now

Firms that have not yet done so should complete a scope assessment now to determine whether they are a Tranche 2 reporting entity. This assessment clarifies whether the firm’s activities fall within the expanded definition of a reporting entity under the reformed AML/CTF Act.

Captured firms need an AML/CTF program — an ML/TF risk assessment and AML/CTF policies — that addresses all designated services they provide, together with customer due diligence procedures (KYC) that meet the new requirements.

A training program for staff is also essential. This program should cover all personnel who provide designated services or have AML/CTF responsibilities. Firms must enrol with AUSTRAC within 28 days of first providing a designated service; a firm that missed that date should enrol now. The whole program must then be independently evaluated at least once every 3 years (first evaluations for newly regulated entities fall due between 30 June 2029 and 31 December 2030).