Does Tranche 2 apply to my business?

It applies if your business provides a 'designated service' as defined in the AML/CTF Act 2006 (Cth). For Tranche 2, this includes real estate agents conducting conveyancing, accountants providing company/trust formation services, lawyers providing conveyancing or trust services, and trust and company service providers. Check the AUSTRAC designated services list or seek legal advice if your scope is borderline.

What is the difference between enrolment and registration?

Enrolment is the first step - it notifies AUSTRAC that your business provides designated services. Registration (a separate, higher-level obligation) applies only to reporting entities providing certain high-risk services such as remittance or digital currency exchange. Most Tranche 2 entities need to enrol, not register.

What must an AML/CTF programme contain?

At minimum: a business risk assessment identifying ML/TF risks; Part A (customer due diligence procedures); Part B (employee due diligence and training); an appointed compliance officer; transaction monitoring processes; and a suspicious matter reporting procedure. AUSTRAC guidance for each sector is available at austrac.gov.au.

What happens if I miss the enrolment deadline?

Failure to enrol by 29 July 2026 is an offence under the AML/CTF Act. AUSTRAC can issue infringement notices, civil penalties, or refer matters for criminal prosecution in serious cases. For most small businesses the risk is a formal warning or civil penalty - but non-compliance after a grace period is taken seriously.

1 Jul 2026

AUSTRAC Tranche 2 - AML/CTF for real estate, accountants, lawyers

Real estate agents, accountants, and lawyers become reporting entities under the AML/CTF Act. Customer due diligence, suspicious-matter reporting, and AUSTRAC enrolment all commence. Phased: enrolment opens earlier in 2026; full obligations from 1 July.

What this means for your business

AUSTRAC Tranche 2 extends Australia's Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) regime to a new category of businesses called 'Tranche 2 entities'. From 1 July 2026, real estate agents, accountants, lawyers, conveyancers, and trust and company service providers that provide designated services must comply with the full AML/CTF framework - including customer due diligence (CDD), transaction monitoring, suspicious matter reporting, and AUSTRAC enrolment.

Enrolment with AUSTRAC opened on 31 March 2026 and must be completed by 29 July 2026. Enrolment is separate from having a compliant AML/CTF programme - the programme itself must be in place by 1 July 2026. A programme must be in writing, risk-based, and regularly reviewed. It must identify, mitigate, and manage the money laundering and terrorism financing risks your business faces.

The most common gaps for newly captured businesses are: no written AML/CTF programme, no designated AML/CTF compliance officer, no customer due diligence procedures, no suspicious matter reporting process, and no staff training records. AUSTRAC has published guidance for each of the new sectors, and the Nifty Computing AML/CTF Program Wizard can help real estate agencies generate a starting-point programme document.

What your business needs to do

Confirm whether your business provides a 'designated service' under the AML/CTF Act - check the AUSTRAC Tranche 2 sector pages for your industry.
Enrol with AUSTRAC by 29 July 2026 via the AUSTRAC Online portal (austrac.gov.au). Enrolment is free and completed online.
Appoint an AML/CTF Compliance Officer (can be the business owner for small operators) and document the appointment.
Draft or adopt an AML/CTF programme by 1 July 2026. It must be in writing, risk-based, and cover customer due diligence, transaction monitoring, and suspicious matter reporting.
Train all relevant staff on AML/CTF obligations before 1 July 2026 and keep training records.

Compliance FAQ

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Written by Tim Jones, Founder & Principal Consultant, Nifty Computing

Published 22 April 2026 · Last reviewed 5 May 2026

Applies to: Australia (all states and territories)

Sources: AUSTRAC, AML/CTF Act 2006 (Cth)

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