Tranche 2 AML compliance is now in effect

Plain-language guide

What is Tranche 2?

Australia's anti-money laundering laws are expanding. If you work in real estate, legal, accounting, or conveyancing services, you'll need to meet new AML/CTF obligations starting July 1, 2026, and we'll explain what that actually means.

What is Tranche 2 and AML/CTF?

Tranche 2 refers to the expansion of Australia's Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Act to include additional professions and industries. It brings real estate agents, lawyers, accountants, and other "gatekeeper" professions under AUSTRAC regulation to detect and prevent financial crime.

The legislation passed Parliament on 29 November 2024 and received Royal Assent on 10 December 2024. These professions will become "reporting entities" under AUSTRAC, joining banks, casinos, and other financial institutions already regulated under Tranche 1.

Tranche 2 requires businesses and professionals to verify customer identities, conduct risk assessments, monitor transactions, report suspicious activity to AUSTRAC, and maintain comprehensive compliance records.

Who Needs to Comply with Tranche 2?

Tranche 2 applies to specific professions that act as "gatekeepers" to the financial system. If you work in any of these industries and provide designated services, you'll need to comply:

If you handle client funds, facilitate large transactions, or provide high-risk financial services, these rules likely apply to you. If you're unsure whether Tranche 2 applies to your business, use AUSTRAC's online eligibility checker or contact us for guidance.

Tranche 2 Timeline & Key Dates

The legislation has passed and the obligations are now in force. Here are the key dates:

Tranche 2 obligations commenced on 1 July 2026

They now apply to newly covered professions.

2025

  • JunePublic consultation on draft rules
  • AugustFinal AML/CTF Rules published
  • SeptemberLearn about the changes in detail
  • DecemberSector-specific guidance finalized

2026

  • JanuaryChoose AML provider or develop internal processes
  • March 31Formal AUSTRAC enrolment opens
  • April–MayFinish system setup and trial run
  • July 1OBLIGATIONS COMMENCECOMPLIANCE DEADLINE

Instant Compliance offers software tools to help you prepare.

  • 1 July 2026: Tranche 2 obligations begin (COMPLIANCE DEADLINE)
  • 31 March 2026: AUSTRAC enrolment opens
  • 29 July 2026: Final deadline to enrol with AUSTRAC

Key Tranche 2 Obligations

What Are the Consequences of Non-Compliance?

Legal consequences

Depending on the nature and severity of the compliance breach, businesses may face:

  • Enforceable undertakings
  • Infringement notices
  • Remedial directions
  • Civil penalty orders
  • Written notices (external auditor, risk assessment)
  • Referral for criminal investigation

Financial penalties

  • Individuals: Up to 20,000 penalty units (currently about $6.6 million) per contravention
  • Body corporate: Up to 100,000 penalty units (currently about $33 million) per contravention
  • Criminal prosecution: Up to 10 years imprisonment for serious offences

Instant Compliance offers software tools to help you prepare, record and manage your AML/CTF program.

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AUSTRAC enforcement guidance

What a Tranche 2 Program Involves

What you would otherwise need to arrange

  • Administration time for record-keeping and reviews
  • Separate software for KYC, KYB, screening and monitoring
  • Professional advice on your program and policies
  • Staff training and a compliance officer appointment
  • Drafting your AML/CTF program and policies
  • Ongoing monitoring and reporting processes

With Instant Compliance

From $69/month +GST (billed annually)

  • Software tools for your Tranche 2 program
  • A library of policy templates you can adapt
  • Risk assessment tools and a draft program document for your review
  • KYC/KYB verification through our partners ($15 +GST per individual check, $30 +GST per business check)
  • Transaction monitoring and report content preparation
  • Staff training modules
  • Australian support team

Professional advice, your compliance officer's time and AUSTRAC enrolment remain your responsibility.

Software tools for Tranche 2 from Instant Compliance

Instant Compliance is built for Australian businesses affected by Tranche 2. Our software is designed with the AML/CTF Act's requirements in mind and gives you workflows for the core parts of your program.

Built for Tranche 2

  • Purpose-designed for Australian regulations
  • Industry-specific workflows for real estate, legal, and accounting
  • Designed with the AML/CTF Act's requirements in mind

Guidance and support

  • Designed for busy professionals, not compliance experts
  • Step-by-step guidance
  • Australian support team

Tranche 2 AML/CTF FAQs

Still have questions? Contact our team

Ready to get started?

Start your free trial of Instant Compliance: software tools for the core parts of your AML/CTF program.

Australian-owned and operated

Important: Instant Compliance is software, not compliance advice.

Our tools help you prepare, record and manage an AML/CTF program. They do not provide legal or compliance advice and do not guarantee compliance with the AML/CTF Act. Your business remains responsible for meeting its own obligations and for every decision it makes using these tools. Instant Compliance is an independent software provider and is not affiliated with, endorsed by or acting on behalf of AUSTRAC or any government body. Read what we do and what stays your responsibility