Tranche 2
The Tranche 2 law asks designated service providers to do four things:
- Establish a program, a requirement
- Do your due diligence, always
- Perform enhanced due diligence, when necessary
- Report to AUSTRAC, when required
The new designated service providers…
From 1 July 2026, you are considered a designated service provider if you work as a:
- Real estate agents or property developer
- Dealer in precious stones, metals and products
- Lawyer
- Conveyancer
- Accountant
- Trust and company service provider
You must establish a program…
As a designated service provider, you must establish a comprehensive program for your business. This program needs to clearly document how you address money laundering and terrorism financing risks that your business may be exposed to.
You can complete our online questionnaire, and receive your custom program for a fraction of the price.
You must do your due diligence…
The Tranche2 law says that you must perform a Verification of Identity (VOI) or a Politically Exposed Persons (PEPs) check on your clients.
There are many providers on the market that can help you to perform this due diligence step.
Our program tells you when you must do these checks and how you are supposed to review them.
You might need to perform enhanced due diligence…
When you identify red flags associated with your client you might need to perform enhanced due diligence steps.
Again, there are many providers on the market that can help you to perform this enhanced due diligence step.
Our program tells you what additional steps you need to perform.
You must report to AUSTRAC…
As you identify suspicious activities and red flags you need to report them to AUSTRAC.
You also need to keep records of checks you perform, and submit annual reports to AUSTRAC.
Our program tells you how to submit reports to AUSTRAC, and respond to any questions that might arise, ensuring you stay compliant.
Parliament of Australia
This bill amends the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 to: extend the anti-money laundering and counter-terrorism financing (AML/CTF) regime to additional services that are recognised by the Financial Action Task Force as posing high money laundering and terrorism financing risks; reframe and clarify the AML/CTF program and customer due diligence obligations; enable the Australian Transaction Reports and Analysis Centre to require the disclosure of information and conduct examinations; and update the AML/CTF regime to reflect changing business structures, technologies and illicit financing methodologies; and make consequential amendments. Also makes consequential or contingent amendments to 10 other Acts; and repeals the Financial Transaction Reports Act 1988.
Attorney-General’s Department
Find key objectives and measures, including a summary of the changes for each entity.
The Amendment Act extends Australia’s anti-money laundering and counter-terrorism financing regime to a range of new entities from 2026.
Reporting entities will need to take a risk-based approach to their AML/CTF programs, and obligations will be outcome-focused.
Reporting entities will need to verify the identity of their customers and understand the risks involved in providing services to them.
Australia’s AML/CTF regime will be updated to protect this rapidly developing sector against exploitation by criminals.
A simplified value transfer chain concept will capture a broader range of value transfers, including money, virtual assets and property.
If your business provides designated services, you will need to enrol with AUSTRAC and meet certain obligations.
AUSTRAC
The key obligations for businesses regulated by AUSTRAC are:
- Enrol and register with AUSTRAC
- Develop and maintain an AML/CTF program tailored to your business
- Conduct initial and ongoing customer due diligence
- Report certain transactions and suspicious activities
- Make and keep records
In meeting AML/CTF obligations, the relevant laws also provide clear protections for information or documents that may be subject to legal professional privilege.
Understanding and meeting your AML/CTF obligations is essential to protect your business from misuse by criminals and ensure you comply with Australia’s AML/CTF laws.
Law Society of Victoria
The Law Society if Victoria AML/CTF Hub is a one-stop shop for up-to-date information and resources about the impending introduction of Tranche 2 of the AML/CTF framework, which will impact solicitors.
Law Council of Australia
Guidance Notes have been developed which examine AML/CTF principles and areas of potential risk of money laundering and terrorism financing in the legal sector, being legal practices who are associated with transactional work, including the holding, investment, and disbursement of clients’ funds.
What is Tranche 2 compliance, and why does it matter?
Tranche 2 compliance refers to upcoming regulatory changes requiring Designated Non-Financial Businesses and Professions (DNFBPs), such as law firms, real estate agents, accountants, and trust service providers to meet Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) regulations. It matters because non-compliance can result in fines, reputational damage, and even legal action.
Does my business need to comply with Tranche 2 regulations?
If you're in a high-risk industry, such as legal, accounting, real estate, or trust and company services, then yes - your business will likely be required to meet AML/CTF obligations under Tranche 2. If you’re unsure, we can help assess your compliance requirements.
What does compliance involve?
Tranche 2 compliance typically includes:
- Customer Due Diligence (CDD) - Verifying client identities and assessing risk
- Ongoing Monitoring - Keeping an eye on transactions and activities
- Reporting Obligations - Submitting reports on suspicious transactions
- Risk Assessments & AML Programs - Implementing policies to prevent financial crime
- Training Staff - Ensuring your team understands compliance responsibilities
How can Compli3d help my business with compliance?
We take the stress out of compliance by providing:
- Tailored AML/CTF programs designed to fit your business
- Risk assessments to identify vulnerabilities and strengthen compliance
- Technology integration for KYC, transaction monitoring, and reporting
- Ongoing support and training to keep your business up to date
What happens if my business doesn’t comply?
Non-compliance can result in:
- Hefty fines and penalties
- Reputational damage
- Legal action
- Loss of trust from clients and partners. The sooner you put compliance measures in place, the better protected your business will be.
How much does compliance cost?
The cost depends on the size of your business, the level of risk, and the solutions you need. At Compli3d, we offer customized pricing to ensure compliance is both effective and cost-efficient.
Do I need special software for compliance?
Not necessarily. While technology can streamline compliance (e.g., KYC verification, transaction monitoring, automated reporting), we help you find the best solution for your business—whether that means integrating new tools or optimizing your current processes.
Can you train my team on AML/CTF compliance?
Absolutely! We provide customized training programs to ensure your team understands their responsibilities, how to spot risks, and how to comply with regulations.
How long does it take to become compliant?
The timeline depends on your current processes, industry, and risk level. Some businesses may need only a few adjustments, while others might require a complete overhaul. We work efficiently to help you meet compliance deadlines without disrupting your operations.
What’s the difference between AML and KYC?
- AML (Anti-Money Laundering) refers to a broader framework of policies, procedures, and laws designed to prevent financial crime
- KYC (Know Your Customer) is a specific part of AML that focuses on verifying the identity of clients and assessing their risk level. KYC is just one piece of the compliance puzzle - AML covers a wider range of measures, including risk assessments, monitoring, and reporting
What industries will be affected by Tranche 2 reforms?
Tranche 2 reforms primarily impact Designated Non-Financial Businesses and Professions (DNFBPs), including:
- Lawyers and conveyancers
- Real estate agents and property developers
- Accountants and auditors
- Trust and company service providers
- High-value dealers (e.g., jewelers, luxury goods sellers, art dealers)
If your industry is on this list, it’s time to start preparing for compliance.
What is a risk-based approach to compliance?
A risk-based approach means focusing your compliance efforts where the risk of money laundering or financial crime is highest. Instead of treating every client the same, you assess the level of risk they pose and apply appropriate due diligence measures.At Compli3d, we help businesses develop risk-based AML strategies that are practical, efficient, and aligned with regulations.
Will Tranche 2 compliance change in the future?
Yes! Regulations are always evolving as governments tighten financial crime controls. That’s why it’s crucial to stay ahead of changes. At Compli3d, we continuously monitor updates and keep our clients informed and prepared.
Why should I choose Compli3d instead of handling compliance myself?
While it’s possible to manage compliance internally, it’s time-consuming and complex—and getting it wrong can be costly. With Compli3d, you get:
- Expert guidance so you’re never left guessing
- Customised solutions tailored to your business
- Ongoing support to help you adapt to future changes.We make compliance easy, practical, and stress-free, so you can focus on growing your business