New AML/CTF Obligations Have Commenced: What Australian Business Owners Need to Know
From 1 July 2026, Australia's anti-money laundering laws extend to lawyers, accountants, conveyancers, real estate professionals, dealers in precious metals and stones, and trust and company service providers. If your business provides a "designated service," you must enrol with AUSTRAC by 29 July 2026 and have an AML/CTF program in place. Here's how to work out whether you're captured, and what changes even if you're not.
For almost twenty years, Australia's anti-money laundering and counter-terrorism financing regime applied mainly to banks, casinos and financial services. That changed on 1 July 2026. The Tranche 2 reforms bring roughly 80,000 new businesses, the so-called "gatekeeper professions", under AUSTRAC's supervision for the first time.
If you've seen the headlines and felt a flutter of panic, take a breath. This is significant, but it is manageable, and as always, prevention is better than cure. Let's work through it.
Does Tranche 2 apply to my business?
The obligations attach to the services you provide, not your job title or industry label. You are captured if your business provides a "designated service" under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (the Act), which now includes many activities commonly performed by legal practitioners, accountants, conveyancers, real estate professionals, dealers in precious metals and stones, and trust and company service providers.
In practical terms, the kinds of activities that trigger obligations include helping clients buy or sell real estate or a business, forming companies or trusts, managing client money or assets, and acting in certain officeholder arrangements. If your work touches these, you need to map what you actually do against the designated services list and reach a documented conclusion, in or out. If you're a consultant, coach, designer or creative service provider whose work doesn't involve these activities, you are unlikely to be captured. But don't guess: check, and write your reasoning down.
What do captured businesses need to do, and by when?
Three things, in order:
Enrol with AUSTRAC by 29 July 2026. Enrolment opened on 31 March 2026, and if you were providing designated services from 1 July, you have 28 days from commencement to enrol. This is the first hard deadline, and it is the one AUSTRAC has signalled it will watch.
Put your AML/CTF program in place. Every captured business needs a written program with two parts: a money laundering and terrorism financing risk assessment, and policies that address customer due diligence, staff training, reporting and record-keeping. You'll also need to appoint a compliance officer (in a small practice, that may well be you).
Operate it. From now on, captured businesses must verify who their customers are before providing designated services, monitor for and report suspicious matters, report cash transactions of $10,000 or more, and keep records for seven years.
What happens if I miss the deadline?
The penalties under the Act are substantial, but the regulator's stated approach matters here. AUSTRAC has been clear that it does not expect perfection from day one, it expects honest effort. Enforcement attention is directed at businesses that wilfully ignore their obligation to enrol, or that turn a blind eye to money laundering. If you're captured and you act promptly and in good faith, you are exactly the kind of business AUSTRAC has said it wants to support, not pursue. There are free starter kits, sector-specific guidance and webinars available through AUSTRAC to help you get moving.
What you should not do is bury your head in the sand. A missed enrolment isn't a technicality, it's a contravention of the Act, and "I didn't get around to it" is not a defence.
Do I need to re-verify my existing clients?
Generally, no (and this is welcome, practical relief). Customer due diligence is not required for client relationships that were established before 1 July 2026, unless a suspicious matter report becomes necessary or something significantly changes the client's risk profile. Your compliance effort is forward-looking: it applies to new clients and new matters from commencement.
I'm not captured — does any of this affect me?
Yes, in one everyday way: your professional advisers are now regulated. When your lawyer, accountant or conveyancer asks you for identification documents, information about your company or trust structure, or the source of funds for a transaction, that's not them being difficult, it's them complying with the law. Expect a little more paperwork when you next buy or sell a business, purchase property, or set up a new entity. Building a few extra days into your transaction timelines is a small, sensible adjustment.
There's also a quiet lesson here for every business owner: regulatory change arrives whether you're watching or not. The businesses that handled Tranche 2 well are the ones that treated compliance as foundation work, not fire-fighting. Has your legal foundation grown with your business?
Where to from here
If you think you may be captured and haven't yet enrolled, the 29 July deadline is close but achievable, start with AUSTRAC's enrolment checker and starter kits today, and get advice on your specific position. If you're clearly outside the regime, file this under "good to know" and carry on.
And if you're not sure which camp you're in, that uncertainty is itself the thing to resolve this week, a short, documented scoping exercise now is far cheaper than an AUSTRAC conversation later. This is precisely the kind of question a fractional in-house counsel arrangement handles as a matter of course.
This article provides general information only and does not constitute legal advice. Your obligations depend on your specific circumstances.
Frequently asked questions
When did Tranche 2 obligations start?
AML/CTF obligations for Tranche 2 entities commenced on 1 July 2026 under the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 (Cth).
What is the AUSTRAC enrolment deadline?
Businesses providing designated services from 1 July 2026 must enrol with AUSTRAC by 29 July 2026, 28 days after commencement.
Who is captured by Tranche 2?
Businesses providing designated services, commonly legal practitioners, accountants, conveyancers, real estate professionals, dealers in precious metals and stones, and trust and company service providers. It's the service, not the profession, that decides.
Do sole practitioners need a compliance officer?
Yes, every captured business needs one, though in a small or sole practice the same person may hold multiple roles, including the principal.
If you have questions or would like our support understanding your obligations, you are welcome to book a time to discuss here.
