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 will be implemented through staged commencement dates spanning 2025 and 2026. This phased approach allows for a managed transition for both existing and newly designated reporting entities.

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

From 31 March 2026, existing reporting entities will transition to the reformed AML/CTF program framework. This means entities must ensure their AML/CTF programs are 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 will 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.

Entities should begin preparations now to ensure compliance by the 31 March 2026 deadline. AUSTRAC enrolment 31 March 2026 walkthrough offers a guide to the enrolment process.

Tranche 2 entities — 1 July 2026

From 1 July 2026, Tranche 2 reporting entities will be 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 entities must now prepare for their obligations. 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, maintaining an AML/CTF program, conducting customer identification, lodging reports, and maintaining records. These requirements are designed to mitigate the risk of money laundering and terrorism financing.

AUSTRAC has indicated a ‘support and educate’ compliance posture in the initial period following the commencement of these obligations. This approach is intended to assist Tranche 2 reporting entities in understanding and meeting their new requirements.

What firms should be doing now

Firms should begin a scope assessment to determine if they will be a Tranche 2 reporting entity from 1 July 2026. This assessment will clarify whether the firm’s activities fall within the expanded definition of a reporting entity under the AML/CTF Act 2024.

Preparation for Tranche 2 implementation requires firms to draft an AML/CTF program that addresses all designated services they will provide. Simultaneously, firms should establish customer identification systems and procedures (KYC) to meet the new requirements.

A training program for staff is also essential. This program should cover all personnel who will provide designated services or have AML/CTF responsibilities. Following the commencement of designated services on or after 1 July 2026, firms must complete AUSTRAC enrolment within 28 days.