Tranche 2 Compliance Checklist for Australian Law Firms
Tranche 2 commenced on 1 July 2026. A last-minute compliance checklist for Australian law firms.
Tranche 2 commenced on 1 July 2026. Australian law firms providing designated legal services must have AUSTRAC enrolment, an approved AML/CTF programme, a named Compliance Officer, and working CDD in place before that date.
What must law firms have in place by 1 July 2026?
Every law firm providing a designated service — conveyancing, trust account management, company or trust formations, managing client funds — 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 services - Customer due diligence — CDD for all clients including beneficial ownership mapping - Staff training — client-facing staff trained before 1 July
What if my firm hasn't enrolled with AUSTRAC yet?
Enrol immediately via AUSTRAC Online — the form takes under an hour. You need your ABN, a list of your designated services, and your principal officer's details. Being unenrolled from 1 July 2026 is a civil penalty offence under the AML/CTF Act 2006.
What if our programme isn't complete?
An incomplete programme is a compliance gap from day one. Focus on the essentials: name your AMLCO, finalise Part A governance, and ensure Part B sets out your CDD procedures. AMLify for law firms generates a compliant programme in under 30 minutes, with senior management approval captured in the same session.
What should my firm do in the next 48 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 and reporting line confirmed in Part A
- Check active matters — CDD on file for any designated service matters in progress
- Brief staff — SMR pathway and tipping-off prohibition understood before the deadline
Key Takeaways
- Two days remain — 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 is not a compliant programme
- Brief your AMLCO and staff — the SMR pathway and tipping-off prohibition must be understood
- [AMLify for law firms](/industries/lawyers) generates a compliant programme and captures approval in under 30 minutes
Frequently Asked Questions
Q: Will AUSTRAC immediately enforce against non-compliant law firms after 1 July 2026?
AUSTRAC will supervise Tranche 2 entities after commencement, but enforcement under Tranche 1 followed engagement and education for firms working in good faith. Being unenrolled or having no programme on 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.
Q: Can AMLify help my law firm get compliant before 1 July 2026?
Yes. AMLify's legal practice 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 — under our Compliance Kickstart offer, firms subscribing by 31 July 2026 receive 30% off for the first six months.
This is general information only and not a substitute for legal advice.