Tranche 2 AML/CTF Guide
Everything you need to know about Australia's expanded anti-money laundering obligations for professional services.
What is Tranche 2?
Tranche 2 is the expansion of Australia's Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) regime to cover professional services sectors that were previously unregulated under this framework.
Since 2006, Australia's AML/CTF laws have applied to financial institutions, gambling providers and bullion dealers. These are known as "Tranche 1" entities.
Tranche 2 extends these obligations to lawyers, accountants, real estate agents, trust and company service providers, dealers in precious metals and stones and other professional service providers. This brings Australia into alignment with international standards set by the Financial Action Task Force (FATF).
Key Dates
Key Dates
31 March 2026
Enrolment opens with AUSTRAC
1 July 2026
Obligations apply from this date
Official sources:
Who Does Tranche 2 Apply To?
Tranche 2 applies to businesses and professionals providing designated services in the following sectors:
Legal
Lawyers, solicitors and legal practitioners
Accounting
Accountants, auditors and tax agents
Real Estate
Real estate agents and agencies
Conveyancing
Licensed conveyancers (NSW, VIC, SA, WA, TAS, NT)
Trust and Company Services
Virtual offices, company registration, corporate trustees
Business Brokers
Share sales and company transfers
Precious Metals and Stones
Dealers in high-value goods
Property Developers
Direct property sellers
Insolvency Practitioners
Administrators, liquidators and receivers
What You Need to Prepare
AML/CTF Program
Documented policies and procedures tailored to your business and risk profile
Risk Assessment
Assessment of money laundering and terrorism financing risks specific to your services
Customer Due Diligence Procedures
Processes for identifying and verifying customers and beneficial owners
Suspicious Matter Reporting
Procedures for identifying, documenting and reporting suspicious matters to AUSTRAC
Record Keeping Systems
Systems to retain required records for a minimum of 7 years
Staff Training
Training program for staff on AML/CTF obligations and your program requirements
Compliance Officer Appointment
Senior manager appointed with responsibility for AML/CTF compliance
AUSTRAC Enrolment
Registration with AUSTRAC as a reporting entity (opens 31 March 2026)
Understanding Your Obligations
Under Tranche 2, reporting entities must implement a comprehensive AML/CTF program that addresses the specific risks of their business. This includes:
- Risk assessment - Identifying and documenting ML/TF/PF risks specific to your business
- Compliance procedures - Customer identification, verification, ongoing monitoring and reporting
The program must be appropriate to the nature, size and complexity of your business and the ML/TF risks you face. AUSTRAC expects a risk-based approach where higher-risk situations receive enhanced scrutiny.
How HeadStart DocsTM Can Help
HeadStart DocsTM provides sector-specific AML/CTF program packs (from $249, or bring your own) and a 31-module compliance portal — free with managed CDD, or run your own CDD on BYO-API plans from $20/month. Documents are yours forever. Our documents include:
- Sector-specific program documents, risk assessments and decision trees (yours forever)
- Free AML Portal and program documents with $35 flat CDD rate. Your client can pay it directly, so your cost is zero.
- 3 sanctions, PEP and adverse media re-screens included per customer. Re-verification (VOI or renewed screening) triggers a new CDD event
- CDD is $35 per customer, pay-as-you-go. Top up your portal credit any time.
- Plug & Play Technology setup in minutes. Immutable audit log from first login.
Frequently Asked Questions
Official Sources
For authoritative information on Tranche 2 requirements, consult these official sources: