Tranche 2 AML refers to the second phase of reforms to Australia’s Anti‑Money Laundering and Counter‑Terrorism Financing (AML/CTF) regime. These reforms extend compliance obligations beyond financial institutions to non‑financial “gatekeeper” professions, including lawyers, accountants, real estate agents and company service providers. From 1 July 2026, affected organisations must as part of their overall obligations implement risk‑based AML/CTF controls, customer due diligence, reporting processes and staff training to meet AUSTRAC expectations.
In practical terms, Tranche 2 brings professional service firms into Australia’s formal AML/CTF supervisory regime for the first time. Organisations must be able to demonstrate compliance with the new laws; not only that policies exist, but that AML/CTF controls are embedded into everyday business activities.
This interactive workshop focuses on the essential frameworks for identifying and managing Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) risks within your organisation.
This practical, instructor led session is designed for Tranche 1 and Tranche 2 reporting entities ( i.e. legal, accounting, conveyancing, real estate and other designated services) that need to build or update their AML/CTF risk assessment in line with AUSTRAC’s expectations.
AML/CTF Risk Assessment Workshop – Sydney, Thursday, 30 April 2026.
Registration for Sydney workshop and EOI for all other States NOW OPEN.
Courses are self-paced, scenario-driven, and suitable for front-line staff, managers, and senior leaders. They can be combined to create a structured, risk-based AML/CTF learning program.
In short: if your organisation facilitates transactions, manages client funds, structures arrangements or provides advisory services that could be exploited for illicit activity, you must prepare now.
Tranche 2 applies to organisations providing designated non‑financial services that present money laundering or terrorism financing risk. These entities have historically operated outside Australia’s AML/CTF regime despite being identified internationally as key “gatekeepers” in the movement and concealment of illicit funds.
The reforms focus on activities that enable criminals to obscure ownership, move funds or legitimise proceeds of crime through trusted intermediaries.
| Sector | Why Included | Key Compliance Impact | Table Header |
|---|---|---|---|
|
Legal |
Gatekeeper to corporate structures |
Shell entities, trusts |
CDD, SMRs, governance |
|
Accounting |
Financial structuring |
Tax evasion |
Risk assessment, monitoring |
|
Real Estate |
High‑value assets |
Property laundering |
Enhanced due diligence |
|
TCSPs |
Entity formation |
Obscured ownership |
Beneficial ownership checks |
AML/CTF obligations under Tranche 2 are activity‑based, not profession‑based. This means obligations are triggered by the services you provide, rather than your professional title alone. An organisation may therefore be subject to AML/CTF requirements for some activities, but not others.
Designated services generally include activities that involve:
Understanding which services fall within scope is critical to determining compliance obligations and designing proportionate controls.
Australia’s Tranche 2 reforms respond to long‑standing recommendations from the Financial Action Task Force (FATF), which identified gaps in Australia’s regulation of non‑financial professions. These gaps created opportunities for criminals to misuse professional services to disguise the origin and ownership of illicit funds.
The reforms are designed to:
AUSTRAC places strong emphasis on governance, accountability and senior leadership oversight under the Tranche 2 regime. Compliance cannot be delegated entirely to frontline staff or external advisers.
Key expectations include:
Strong governance frameworks are essential to demonstrating reasonable steps toward compliance.
AUSTRAC supervision focuses on whether organisations have taken reasonable, risk‑based steps to prevent money laundering and terrorism financing. This includes reviewing documentation, training records, risk assessments and how policies are applied in practice.
Regulators will assess not only whether controls exist, but whether staff understand and consistently follow them. Organisations should expect increased scrutiny during the initial years of Tranche 2 implementation.
Preparing for Tranche 2 requires more than policy updates. Compliance leaders must embed AML/CTF obligations into governance structures, operational processes and workforce capability.
In practice, Tranche 2 compliance requires a proportional and risk‑based approach across people, processes and systems.
Organisations must ensure staff understand their obligations, processes are clearly documented and followed, and systems support record‑keeping, reporting and audit requirements. The scale and complexity of controls should reflect the organisation’s size, risk profile and services offered.
Tranche 2 entities must be able to demonstrate ongoing compliance through documented controls and evidence‑based practices, including:
| Feature | Tranche 1 (2006) | Tranche 2 (2026) |
|---|---|---|
|
Primary sectors |
Banks, casinos, remitters |
AUSTRAC |
|
Regulator |
AUSTRAC |
AUSTRAC |
|
CDD required |
Yes |
Yes |
|
Risk‑based program |
Required |
Required |
|
Training obligation |
Required |
Expanded and emphasised |
Law firms managing client funds, trusts and cross‑border transactions must strengthen governance, documentation and escalation processes to manage heightened regulatory scrutiny.
Accounting practices face increased obligations around advisory services, beneficial ownership verification and identifying suspicious arrangements linked to tax evasion or financial crime.
Real estate professionals must apply enhanced due diligence to high‑value transactions, third‑party purchasers and complex ownership structures.
Organisations often struggle to demonstrate that controls are applied consistently in practice, not just documented on paper.
Without regular refresher training, staff knowledge can quickly become outdated as guidance and expectations evolve.
Larger or decentralised organisations must ensure consistent application of AML/CTF controls across teams and locations.
AUSTRAC expects training to be role‑based, ongoing and auditable. Training is a primary control relied upon to evidence reasonable steps toward compliance and accountability.
Effective AML/CTF training programs include:
GRC Solutions helps organisations move from awareness to operational readiness through an integrated approach to AML/CTF capability building.
Our support includes:
GRC Solutions offers practical AML/CTF learning opportunities to help your organisation implement and operationalise Tranche 2 obligations. Sessions are led by AML and financial crime specialists and can be delivered in person or live online, depending on your needs.
These learning opportunities include:
Our consulting capability spans AML risk assessments, program and framework reviews, gap analysis against evolving AUSTRAC expectations, and the design of uplift roadmaps tailored to organisational size, risk profile, and operating model. This ensures that AML investment is targeted where it matters most—customer due diligence, transaction monitoring oversight, escalation pathways, and board and senior management accountability.
Whether for compliance teams, front-line staff, legal or accounting practices, real estate professionals, or senior leadership, these sessions help your organisation strengthen controls, reinforce obligations, and demonstrate proactive compliance.
A recent professional training announcement in the UK highlights a serious compliance issue facing law firms working under anti-money-laundering (AML) regulations*
The reforms commence on 1 July 2026, with preparation milestones across 2025 and early 2026.
Yes. When providing designated services, both professions become reporting entities under the AML/CTF Act.
Yes. AUSTRAC expects organisations to train staff so they understand and apply AML/CTF obligations in practice.
Designated services are specific non‑financial activities that present AML/CTF risk, such as managing client funds, establishing legal entities or facilitating high‑value transactions.
Approximately 90,000 organisations are expected to fall within scope of the Tranche 2 reforms.
Yes, but controls must be proportionate to size and risk exposure. Smaller firms are still expected to conduct risk assessments, train staff and meet core obligations.
Civil penalties, enforceable undertakings and significant reputational damage may apply.
Preparing early reduces regulatory risk, avoids last‑minute disruption and supports sustainable compliance. GRC Solutions partners with mid‑to‑large organisations to embed AML/CTF capability through training, systems and governance frameworks.
Contact us to discuss your Tranche 2 readiness.
Practical insights on Australia’s AML/CTF obligations and Tranche 2 reforms. Guidance for regulated organisations on compliance, risk management and staff training.
With the introduction of AUSTRAC’s new AML/CTF Rules, Tranche 2 entities — including lawyers, accountants, real estate agents, trust and company service providers, jewellers, and virtual asset businesses — will soon face obligations to identify, mitigate, and manage money laundering and terrorism financing risks.
Australia’s pubs and clubs are more than just places for socialising – when they provide certain financial services, such as operating gaming machines or facilitating electronic funds transfers, they’re also considered reporting entities under the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Act 2006. This means they have serious obligations to detect and prevent financial crime.
A recent professional training announcement in the UK highlights a serious compliance issue facing law firms working under anti-money-laundering (AML) regulations*
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