What Is Tranche 2? A Plain-English Guide for Australian Businesses
Tranche 2 extends AML/CTF obligations to lawyers, accountants, real estate agents, and more. Here is what it means for your business and what you need to do before 1 July 2026.
If you run a law firm, accounting practice, real estate agency, or deal in precious metals or virtual assets in Australia, Tranche 2 of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 is about to change how you do business.
What is Tranche 2?
Australia's AML/CTF Act was originally passed in 2006. Tranche 1 covered financial institutions — banks, credit unions, money transfer services, and gambling operators. Tranche 2 extends these same obligations to designated non-financial businesses and professions (DNFBPs).
The legislation was passed in late 2025, with obligations commencing from 1 July 2026. This gives affected businesses approximately 12 months to become compliant.
Who is affected?
Tranche 2 applies to businesses providing designated services, including:
- Legal practitioners — solicitors, barristers, and conveyancers providing certain legal services
- Accountants — accounting professionals providing certain accounting, tax, and audit services
- Real estate agents — agents involved in buying, selling, or leasing real property
- Trust and company service providers — firms that form companies, act as directors or nominees, or provide registered offices
- Precious metals and stones dealers — businesses that buy or sell precious metals, precious stones, or jewellery
- Virtual asset service providers — cryptocurrency exchanges, custodians, and transfer providers
What do you need to do?
Under Tranche 2, affected businesses must:
- Develop an AML/CTF program — A written compliance program covering risk assessment, CDD procedures, and reporting obligations
- Perform customer due diligence (CDD) — Verify the identity of customers before providing designated services
- Monitor transactions — Implement ongoing monitoring to detect suspicious activity
- Report to AUSTRAC — Submit threshold transaction reports (TTRs), suspicious matter reports (SMRs), and international funds transfer instructions (IFTIs)
- Keep records — Maintain records of CDD, transactions, and reports for at least 7 years
- Train staff — Ensure all employees providing designated services receive AML/CTF training
The timeline
Obligations commence from 1 July 2026. AUSTRAC has indicated a risk-based approach to enforcement in the initial period, but this does not mean businesses can delay preparation. Building an AML/CTF program, training staff, and setting up monitoring systems takes time.
How AMLify helps
AMLify is purpose-built for Tranche 2 businesses. Our AI assistant Ami generates your entire AML/CTF program in under 30 minutes, tailored to your specific industry and services. No compliance expertise required — Ami explains everything in plain English and guides you through every step.
Start your free trial today and be compliant before the deadline.