--- title: "What is AML/CTF Tranche 2? | Complete Guide | HeadStart Docs" description: "What is AML/CTF Tranche 2? Guide for lawyers, accountants, real estate. Enrolment 31 March 2026, obligations 1 July 2026." lang: en-AU json-ld: | [ { "@context": "https://schema.org", "@type": "Organization", "name": "HeadStart Docs", "legalName": "HeadStart Docs Pty Ltd", "url": "https://www.headstartdocs.com.au", "logo": { "@type": "ImageObject", "url": "https://www.headstartdocs.com.au/logo-512.png?v=4", "width": 512, "height": 512 }, "description": "AML/CTF compliance digital products and programs for Australian businesses under Tranche 2 regulations. Free program documents and AML Portal. 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We provide digital products for AML/CTF compliance, not legal services." } }, { "@context": "https://schema.org", "@type": "BreadcrumbList", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://www.headstartdocs.com.au/" }, { "@type": "ListItem", "position": 2, "name": "Shop", "item": "https://www.headstartdocs.com.au/shop" }, { "@type": "ListItem", "position": 3, "name": "Tranche 2 Hub", "item": "https://www.headstartdocs.com.au/tranche-2" }, { "@type": "ListItem", "position": 4, "name": "Sanctions Search", "item": "https://www.headstartdocs.com.au/sanctions-search" } ] }, { "@context": "https://schema.org", "@type": "FAQPage", "mainEntity": [ { "@type": "Question", "name": "Do I still need a solicitor for AML/CTF Tranche 2 compliance?", "acceptedAnswer": { "@type": "Answer", "text": "Yes. HeadStart Docs products are digital publications that give you a substantial head start, but they must be reviewed and tailored by a qualified solicitor to your specific business circumstances before implementation." } }, { "@type": "Question", "name": "How is HeadStart Docs different from the free AUSTRAC Starter Kits?", "acceptedAnswer": { "@type": "Answer", "text": "AUSTRAC Starter Kits are generic starting points that require significant customisation. HeadStart products are sector-specific, pre-populated with industry-relevant risk factors and scenarios, and include 12 months of AML Portal access for ongoing compliance including screening, record keeping and reporting tools." } }, { "@type": "Question", "name": "What if the AML/CTF rules change after I purchase?", "acceptedAnswer": { "@type": "Answer", "text": "Your digital products are yours to keep. If significant regulatory changes occur, updated versions will be available to active portal subscribers. The AML Portal itself is continuously updated to reflect current AUSTRAC requirements and sanctions lists." } }, { "@type": "Question", "name": "What happens after my 12-month AML portal access expires?", "acceptedAnswer": { "@type": "Answer", "text": "Your documentation is yours forever. To continue using the AML Portal (screening tools, compliance calendar, record keeping), you pay $35 per customer CDD. Cancel anytime — no subscription required." } }, { "@type": "Question", "name": "Is HeadStart Docs a law firm?", "acceptedAnswer": { "@type": "Answer", "text": "No. HeadStart Docs is a digital publisher and platform provider. We sell digital compliance products and portal access. We do not provide legal advice. Referrals for legal advice can be made to our related law firm, HeadStart Counsel." } }, { "@type": "Question", "name": "When does AML/CTF Tranche 2 commence in Australia?", "acceptedAnswer": { "@type": "Answer", "text": "Tranche 2 AML/CTF obligations commence on 1 July 2026. All reporting entities in designated sectors including lawyers, accountants, real estate agents, conveyancers, and trust and company service providers must have their AML/CTF programs in place by this date." } } ] }, { "@context": "https://schema.org", "@type": "BreadcrumbList", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://www.headstartdocs.com.au/" }, { "@type": "ListItem", "position": 2, "name": "Tranche 2 Guide", "item": "https://www.headstartdocs.com.au/tranche-2" } ] }, { "@context": "https://schema.org", "@type": "FAQPage", "mainEntity": [ { "@type": "Question", "name": "What is Tranche 2?", "acceptedAnswer": { "@type": "Answer", "text": "Tranche 2 refers to the extension of Australia's Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) regime to professional services sectors. Previously, these obligations only applied to financial institutions and gambling providers. From 1 July 2026, additional sectors including lawyers, accountants, real estate agents and others will be required to comply." } }, { "@type": "Question", "name": "When do Tranche 2 obligations start?", "acceptedAnswer": { "@type": "Answer", "text": "Tranche 2 obligations apply from 1 July 2026. AUSTRAC enrolment opens on 31 March 2026. Many firms are developing their AML/CTF programs now to allow time for legal review before the deadline. This is general information only – seek advice specific to your circumstances." } }, { "@type": "Question", "name": "Do I need to enrol with AUSTRAC?", "acceptedAnswer": { "@type": "Answer", "text": "Yes. All reporting entities under Tranche 2 must enrol with AUSTRAC. The enrolment portal opens 31 March 2026. You must be enrolled before 1 July 2026 when obligations commence." } }, { "@type": "Question", "name": "What is an AML/CTF program?", "acceptedAnswer": { "@type": "Answer", "text": "An AML/CTF program is a documented set of policies, procedures and controls designed to identify, mitigate and manage money laundering and terrorism financing risks. It includes customer due diligence procedures, ongoing monitoring, suspicious matter reporting processes and staff training requirements." } }, { "@type": "Question", "name": "What services trigger AML/CTF obligations?", "acceptedAnswer": { "@type": "Answer", "text": "Specific designated services within each sector trigger obligations. For lawyers, this includes conveyancing and trust account management. For accountants, it includes certain financial services. The exact scope varies by sector and is defined in the AML/CTF Act and Rules." } }, { "@type": "Question", "name": "What are the penalties for non-compliance?", "acceptedAnswer": { "@type": "Answer", "text": "Penalties for non-compliance can include civil penalties of up to $555,000 per contravention for individuals and significantly higher for corporations. AUSTRAC also has powers to issue infringement notices, enforceable undertakings and in serious cases, pursue criminal prosecution." } }, { "@type": "Question", "name": "Do I need a compliance officer?", "acceptedAnswer": { "@type": "Answer", "text": "Yes. Tranche 2 entities must appoint an AML/CTF compliance officer at senior management level who is responsible for the implementation and oversight of your AML/CTF program. This person must have appropriate authority and independence to carry out their duties." } }, { "@type": "Question", "name": "What customer due diligence (CDD) is required?", "acceptedAnswer": { "@type": "Answer", "text": "CDD requirements include identifying customers and verifying their identity, identifying beneficial owners of entities, assessing the ML/TF risk of customer relationships, and conducting ongoing monitoring. Enhanced due diligence is required for higher-risk customers such as politically exposed persons (PEPs)." } }, { "@type": "Question", "name": "What records must I keep?", "acceptedAnswer": { "@type": "Answer", "text": "You must retain records of customer identification and verification, transactions, suspicious matter reports and AML/CTF program documents for a minimum of 7 years. Records must be accessible to AUSTRAC upon request." } }, { "@type": "Question", "name": "Where can I find official guidance?", "acceptedAnswer": { "@type": "Answer", "text": "Official guidance is available from AUSTRAC at austrac.gov.au. AUSTRAC publishes regulatory guides, kits tailored to each sector and FAQs. You should also consult with qualified legal professionals for advice tailored to your circumstances." } } ] }, { "@context": "https://schema.org", "@type": "WebPage", "name": "AML/CTF Tranche 2 Guide for Australian Businesses", "description": "What is Tranche 2? Complete guide to AML/CTF obligations for Australian lawyers, accountants, real estate agents. Key dates: obligations commence 1 July 2026.", "url": "https://www.headstartdocs.com.au/tranche-2", "publisher": { "@type": "Organization", "name": "HeadStart Docs" } }, { "@context": "https://schema.org", "@type": "HowTo", "name": "How to Comply with AML/CTF Tranche 2 in Australia", "description": "Complete step-by-step guide for Australian professionals to prepare for Tranche 2 AML/CTF obligations before July 2026.", "totalTime": "P90D", "step": [ { "@type": "HowToStep", "position": 1, "name": "Determine if your sector is covered", "text": "Check if your business provides designated services under Tranche 2: lawyers, accountants, real estate agents, conveyancers, TCSPs, business brokers, precious metals dealers, property developers, or insolvency practitioners.", "url": "https://www.headstartdocs.com.au/tranche-2" }, { "@type": "HowToStep", "position": 2, "name": "Conduct a risk assessment", "text": "Assess money laundering and terrorism financing risks relevant to your services, clients and geographic exposure." }, { "@type": "HowToStep", "position": 3, "name": "Develop your AML/CTF program", "text": "Create documented policies and procedures tailored to your business and risk profile. HeadStart Docs™ provides free frameworks for each sector.", "url": "https://www.headstartdocs.com.au/programs" }, { "@type": "HowToStep", "position": 4, "name": "Appoint a compliance officer", "text": "Designate a senior manager as your AML/CTF compliance officer with appropriate authority and independence." }, { "@type": "HowToStep", "position": 5, "name": "Implement customer due diligence", "text": "Establish procedures for identifying and verifying customers and beneficial owners before providing designated services." }, { "@type": "HowToStep", "position": 6, "name": "Set up record keeping", "text": "Implement systems to retain required records for a minimum of 7 years in accessible format." }, { "@type": "HowToStep", "position": 7, "name": "Train your staff", "text": "Develop and deliver AML/CTF training for all relevant staff members." }, { "@type": "HowToStep", "position": 8, "name": "Enrol with AUSTRAC", "text": "Register as a reporting entity when the portal opens on 31 March 2026, before the 29 July 2026 deadline." } ], "author": { "@type": "Organization", "name": "HeadStart Docs" } }, { "@context": "https://schema.org", "@type": "BreadcrumbList", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://www.headstartdocs.com.au/" }, { "@type": "ListItem", "position": 2, "name": "Home", "item": "https://www.headstartdocs.com.au/" }, { "@type": "ListItem", "position": 3, "name": "Tranche 2 Guide", "item": "https://www.headstartdocs.com.au/tranche-2" } ] } ] --- [Get Started ](/checkout) We use cookies to enhance your experience and analyse traffic. [Privacy Policy](/privacy) Essential OnlyAccept All [Skip to main content](#main-content) [ ![HeadStart Docs](/assets/logo-dark-bg-CUivuKJ8.png)![HeadStart Docs](/assets/logo-light-bg-D5BRMGqf.png) ](/) [Home ](/) Features [Programs ](/programs) Resources Sectors [Log in ](/auth) [Portal](/aml-landing) 1. [](/) - [Home](/) - Tranche 2 Guide Complete Guide # Tranche 2 AML/CTF Guide Everything you need to know about Australia's expanded anti-money laundering obligations for professional services. General information only. Not legal advice. Always take specific advice for your circumstances. ## 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: [AUSTRAC Reform](https://www.austrac.gov.au/about-us/amlctf-reform) [Summary of Obligations](https://www.austrac.gov.au/about-us/amlctf-reform/reforms-guidance/before-you-start/summary-obligations-reform) [Home Affairs Overview](https://www.homeaffairs.gov.au/about-us/our-portfolios/criminal-justice/anti-money-laundering-and-counter-terrorism-financing/anti-money-laundering-and-counter-terrorism-financing-amendment-act/overview-of-the-aml-ctf-amendment-act) General information only. Not legal advice. Digital products must be tailored and reviewed for your circumstances. [View full implementation timeline](/timeline) ## 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 ](/law-practice)[ ### Accounting Accountants, auditors and tax agents ](/accounting)[ ### Real Estate Real estate agents and agencies ](/real-estate)[ ### Conveyancing Licensed conveyancers (NSW, VIC, SA, WA, TAS, NT) ](/conveyancing)[ ### Trust and Company Services Virtual offices, company registration, corporate trustees ](/tcsp)[ ### Business Brokers Share sales and company transfers ](/business-brokers)[ ### Precious Metals and Stones Dealers in high-value goods ](/precious-metals)[ ### Property Developers Direct property sellers ](/property-developers)[ ### Insolvency Practitioners Administrators, liquidators and receivers ](/insolvency-practitioners) ## 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. [Browse our resource library](/resources) ## 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. HeadStart Docs compliance documents require legal review and tailoring to your specific circumstances before use. [View Program Packs](/programs)[Access AML Portal](/aml-landing) ## Frequently Asked Questions ### What is Tranche 2? ### When do Tranche 2 obligations start? ### Do I need to enrol with AUSTRAC? ### What is an AML/CTF program? ### What services trigger AML/CTF obligations? ### What are the penalties for non-compliance? ### Do I need a compliance officer? ### What customer due diligence (CDD) is required? ### What records must I keep? ### Where can I find official guidance? ## Official Sources For authoritative information on Tranche 2 requirements, consult these official sources: [AUSTRAC Reform Hub](https://www.austrac.gov.au/about-us/amlctf-reform) [Summary of Obligations](https://www.austrac.gov.au/about-us/amlctf-reform/reforms-guidance/before-you-start/summary-obligations-reform) [Home Affairs Overview](https://www.homeaffairs.gov.au/about-us/our-portfolios/criminal-justice/anti-money-laundering-and-counter-terrorism-financing/anti-money-laundering-and-counter-terrorism-financing-amendment-act/overview-of-the-aml-ctf-amendment-act) This guide provides general information only and is not a substitute for legal advice. The information may not be complete, current, or applicable to your specific situation. Always consult with qualified legal and compliance professionals for advice specific to your circumstances. ![HeadStart Docs](/assets/logo-dark-bg-CUivuKJ8.png)![HeadStart Docs](/assets/logo-light-bg-D5BRMGqf.png) [![HeadStart Counsel](/assets/headstart-counsel-logo-dark-DW8mV5rY.png)](https://www.headstartcounsel.com.au/)[![HeadStart Search](/assets/headstart-search-logo-dark-C68UhGXl.png)](/sanctions-search)![HeadStart Verify](/assets/headstart-verify-dark-Dtad3197.png) ### Sectors [Accounting](/accounting)[Business Brokers](/business-brokers)[Buyers Agent](/programs/buyers-agent-aml-program)[Conveyancing](/conveyancing)[Insolvency](/insolvency-practitioners)[Legal](/law-practice)[Nominee Director](/programs/nominee-director-aml-program)[Precious Metals, Stones & Products](/precious-metals)[Property Development](/property-developers)[Real Estate](/real-estate)[TCSPs](/tcsp)[Virtual Address](/virtual-address) ### Resources [Free Resources](/tranche-2-resources)[Decision Trees](/decision-trees)[Tranche 2 Guide](/tranche-2)[Podcast](/podcast)[Free Sector Reports](/sector-reports)[Implementation Timeline](/timeline)[Sanctions Search](/sanctions-search)[AUSTRAC Starter Kits](/tranche-2-resources/austrac-starter-program-kits)[Budgeting for Compliance](/tranche-2-resources/budgeting-amlctf-compliance) ### Programs [Portal + AML Programs](/programs)[Pricing](/pricing)[White Label](/white-label)[External CRMs](/integrations)[AML Portal](/aml-landing)[Plug & Play Technology](/plug-and-play)[Lawyer in the Loop](/features/lawyer-in-the-loop) ### Legal [Terms & Conditions](/terms)[Privacy](/privacy) ### Connect [Programs](/programs)[Podcast](/podcast)[Feedback](/report-problem)[Our Mission](/our-mission)[Partnerships](/partnerships) ### Events [AML Conference 2026](/conference) Powered by Stripe SSL Secured 2026 Ready © HeadStart Docs Pty Ltd (ABN 12 691 347 823). HeadStart Docs™ is a digital publisher and platform provider. We sell digital compliance products including publications and portal access to our AML Portal; we do not provide legal advice or services. The content on this website and in our products is for general information purposes only, does not consider your individual and business circumstances, and should not be relied on as legal advice. Referrals for legal advice can be made, on request, to HeadStart Counsel, the registered trading name of Astris Law Pty Ltd, a related incorporated legal practice with the same director and beneficial owner as HeadStart Docs. You are free to engage any legal practitioner of your choice.