Tranche 2 Compliance Checklist for Accountants
The Tranche 2 AML/CTF deadline is 1 July 2026 — one day away. A last-day compliance checklist for Australian accounting firms.
The Tranche 2 AML/CTF deadline is 1 July 2026 — one day from today. Australian accounting firms providing designated services must have AUSTRAC enrolment, an approved AML/CTF programme, a named Compliance Officer, and working CDD in place before that date.
What must accounting firms have in place by 1 July 2026?
Every accounting firm providing a designated service — managing client funds, company or trust formation, real property transactions, or business acquisitions — must have in place: - AUSTRAC enrolment — registered through AUSTRAC Online - AML/CTF programme — written Part A (governance) and Part B (CDD procedures) - AML/CTF Compliance Officer — named in Part A - ML/TF risk assessment — documented and calibrated to your designated services - Customer due diligence — CDD workflows for all clients, including beneficial ownership mapping - Staff training — all client-facing staff trained before 1 July
What if my firm hasn't enrolled with AUSTRAC yet?
Enrol immediately through AUSTRAC Online — the form takes under an hour. You need your ABN, a list of your designated services, and your principal officer's details. Providing a designated service from 1 July 2026 without AUSTRAC enrolment is a civil penalty offence under the AML/CTF Act 2006, with penalties that can reach $18.5 million per contravention for corporate entities.
What if our programme isn't complete?
An incomplete programme is a compliance gap from the first day of the new regime. With one day left, focus on the essentials: name your AMLCO in Part A, confirm the customer acceptance policy, and ensure Part B sets out your CDD procedures for each designated service. AMLify for accountants generates a compliant Part A and Part B in under 30 minutes, with senior management approval captured in the same session.
What should my firm do in the next 24 hours?
- Confirm enrolment — verify your firm is listed as an enrolled entity on AUSTRAC Online
- Approve your programme — Part A and Part B signed off by senior management before 1 July
- Document your AMLCO — responsibilities, reporting line, and authority confirmed in Part A
- Check active client matters — CDD on file for any designated service matters currently in progress
- Brief staff — the SMR pathway and tipping-off prohibition must be understood before the deadline
Key Takeaways
- One day remains — enrolment, an approved programme, and functioning CDD are mandatory from 1 July 2026
- Enrol via AUSTRAC Online now if your firm is not yet registered — the form takes under an hour
- Approve Part A and Part B before the deadline — a programme in draft form is not a compliant programme
- Brief your AMLCO and staff — the SMR pathway and tipping-off prohibition must be understood before go-live
- [AMLify for accountants](/industries/accountants) generates a compliant programme and captures approval in under 30 minutes
Frequently Asked Questions
Q: Will AUSTRAC immediately penalise non-compliant accounting firms after 1 July 2026?
AUSTRAC will supervise Tranche 2 entities after commencement, but its approach under Tranche 1 was to engage before escalating to formal enforcement for firms working in good faith. Being unenrolled or operating without a programme from 1 July is a civil penalty offence under the AML/CTF Act 2006. Active, documented compliance effort makes a material difference to how AUSTRAC treats a firm in early supervision.
Q: Is there a grace period after the Tranche 2 deadline?
No formal grace period exists. Obligations are operative from 1 July 2026. AUSTRAC's historical approach has been to engage before escalating to formal enforcement for firms demonstrating good-faith compliance work — but that is discretion, not a legal right. Accounting firms should treat the deadline as hard.
Q: Can AMLify help my accounting firm get compliant before 1 July 2026?
Yes. AMLify's accountants module generates a compliant Part A and Part B programme in under 30 minutes and captures AMLCO appointment and senior management approval in the same session. A 14-day free trial is at /pricing — firms subscribing before the deadline receive 40% off for the first six months.
This is general information only and not a substitute for legal advice.