Tranche 2
Tranche 2 deadlines: obligations already apply.
The key Tranche 2 dates have passed and the obligations are in force. Here is what each date meant, who is covered and what to do now.
Key dates
Key dates, already in force.
31 March 2026
Reform changes started for existing reporting entities, unless deferred under transitional rules.
1 July 2026
Businesses newly regulated because they provide designated services, such as certain real estate, legal, accounting, conveyancing and trust and company services, became subject to AML/CTF obligations.
29 July 2026
Enrolment deadline for established newly regulated businesses already providing designated services on 1 July 2026. It is not a rolling deadline for businesses that start later.
Who's covered
Is your business in scope?
- Real estate agents brokering the sale, purchase or transfer of real estate
- Lawyers and conveyancers, for the designated services they provide
- Accountants, for designated services such as creating or restructuring entities
- Trust and company service providers
- Dealers in precious metals and stones
Whether you're covered depends on the services you provide, not just your job title. Check AUSTRAC's guidance for your situation.
Penalties
Why it matters.
AUSTRAC can issue infringement notices, enforceable undertakings and remedial directions, and courts can order significant civil penalties. Some breaches are also criminal offences. Getting the basics in place early is the best protection.
Your obligations
The 7 obligations.
- 1
Enrol with AUSTRAC
Reporting entities must enrol with AUSTRAC. Enrolment is different from registration, which usually only applies to remittance and virtual asset services. Check AUSTRAC guidance for when enrolment is due if you start providing designated services after 1 July 2026.
- 2
Assess your ML/TF risk
Understand how your business could be misused by criminals.
- 3
Have an AML/CTF program
Written policies and processes to manage those risks.
- 4
Customer due diligence
Generally before providing a designated service: identify and verify customers, beneficial owners and people acting for them, subject to AUSTRAC exceptions.
- 5
Monitor on an ongoing basis
Keep an eye on customers and transactions over time.
- 6
Report to AUSTRAC
Lodge suspicious matter and threshold transaction reports when needed.
- 7
Keep records and train staff
Keep records for the required periods (for example, CDD records generally 7 years after the relationship ends or the last occasional transaction), appoint a compliance officer and train your team.
Checklist
6 steps to get started.
0 of 6 done.
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Next: check your gaps with the readiness checker, then try the risk assessment or the program starter.
General information only, not legal advice.
This tool gives general information to help you get started. It is not legal advice, has not been reviewed or approved by AUSTRAC, and using it does not by itself meet your AML/CTF obligations. Check AUSTRAC guidance and speak with a qualified adviser about your business.