Tranche 2 AML/CTF Reforms in Australia: Key Insights for businesses

From 1 July 2026, Australia’s anti-money laundering (AML) and counter-terrorism financing (CTF) framework will undergo one of its most significant expansions in decades. The “Tranche 2” reforms will bring thousands of new businesses under AUSTRAC’s regulatory scope for the first time, reshaping compliance expectations across multiple industries. If your business operates in real estate, legal, accounting, precious metals, or trust and company services, now is the time to understand whether you will be affected and what you need to do to prepare.

What are the Tranche 2 AML/CTF Reforms?

The Tranche 2 reforms are the next major stage of Australia’s AML/CTF regime expansion. They are designed to close regulatory gaps and will impact a large group of businesses known as designated non-financial businesses and professions (DNFBPs).
These reforms will apply to industries that have not previously been subject to the same compliance standards as banks and financial institutions.

Which Businesses Will Be Affected?

The reforms will apply to the following DNFBPs:

  • Real estate agents and property managers involved in buying, selling, or leasing property
  • Lawyers and conveyancers assisting with property transactions, company formation, or trust management
  • Accountants providing tax advice, company setup, or trust-related services
  • Dealers in precious metals and stones handling high-value transactions
  • Trust and company service providers offering entity formation or registered office services

If your business operates in any of these areas, you are likely to fall within AUSTRAC’s regulatory scope.

What are the key AML/CTF Obligations?

AML/CTF Program

Businesses must establish and maintain a documented AML/CTF program that is approved by senior management and reviewed regularly. The program should reflect the size, complexity, and risk profile of the business.

Customer Due Diligence (CDD)

You will need to verify your customers’ identities and understand who ultimately owns or controls an entity. CDD also includes assessing the purpose and nature of the business relationship.

Ongoing Monitoring

Compliance does not end at onboarding. Businesses must continuously monitor customer activity, keep records up to date, and apply enhanced checks where higher risks are identified.

Suspicious Matter Reporting

If you suspect that a transaction or customer may involve money laundering or terrorism financing, you must submit a Suspicious Matter Report (SMR) to AUSTRAC within the required timeframe.

Record Keeping

Detailed records must be retained for at least seven years, including customer identification records, transaction records, and AML/CTF program documentation.

How Can Businesses Prepare for Tranche 2?

Preparing early is essential. Businesses should take the following steps:

  • Review your services to determine where obligations apply
  • Conduct a risk assessment tailored to your business model
  • Develop a fit-for-purpose AML/CTF program
  • Train staff so they understand their compliance responsibilities
  • Implement systems to support due diligence, monitoring, reporting, and record keeping

Early preparation will make compliance more manageable and reduce last-minute disruption as the reforms take effect.

How NextGen AML Can Help

NextGen AML supports businesses navigating Tranche 2 requirements with end-to-end solutions:

  • Expert consultancy to design and implement your AML/CTF program
  • Practical training to upskill your team
  • A compliance platform to streamline customer due diligence and reporting

Getting the right support in place now will help your business prepare confidently and avoid costly surprises. 

Answers, before you ask.

What is Tranche 2 AML/CTF?

Tranche 2 is the expansion of Australia’s AML/CTF regime to include new business sectors such as real estate, legal, accounting, and trust service providers.

Do small businesses really need AML/CTF controls?
Yes. Businesses that provide AUSTRAC defined designated services must incorporate AML/CTF Controls. These include and are not limited to Real Estate Agents and Agencies, Lawyers and Conveyancers and Accounting Practitioners. AUSTRAC has mandated that all new regulated entities should be ready to meet compliance guidelines by the 1st July, 2026. All businesses must comply, regardless of size.
Is NextGenAML suitable for real estate agencies?
Yes, NextGen AML is purpose built for the Real Estate agents and agencies. Our workflows are designed around entity checks, beneficial ownership, risk scoring, document collection and verification. We also are aware of specific industry requirements that might require multiple buyer profiles and checks.
Can NextGenAML support accounting firms?
Yes. The platform supports Accounting Firms and Accountants with client onboarding, KYB, entity verification, beneficial owner capture, risk assessments, PEP screening and audit ready record keeping. It is aligned with requirements of the industry and is calibrated to the engagement requirements of your business.

Date published

08/01/2026

Time to read

8 minute read

Author

NextGen AML

Team

Locations

Australia

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