— days until enrolment cutoff 29 July 2026

Tranche 2 AML/CTF Reforms are LIVE – are your processes in place?

Since 1 July 2026, Australia’s Tranche 2 AML/CTF reforms have significantly expanded the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) regime to include professional service providers across property and real estate, accounting and corporate services, tax, insolvency, legal and advisory firms and many more small to medium enterprise.

Over 100,000 firms are now “reporting entities” under the AML/CTF Act and are required to implement comprehensive compliance and reporting frameworks.

Penalties for non-compliance are severe.

Your obligations

Key AML/CTF Requirements before 29 July 2026 (practical cut-off for enrolment)

Firms that provide one or more “designated service” under the AML/CTF Act must prepare for the following mandatory obligations:

Enrol with AUSTRAC as a reporting entity
Implement a tailored AML Program
Appoint a fit and proper AML/CTF Compliance Officer (AMLCO)
Conduct personnel due diligence on relevant staff
Ensure board members and staff receive AML/ CTF training
Conduct initial customer due diligence (CDD) before providing a designated service
Apply customer risk assessment methodologies
Conduct politically exposed person (PEP) and financial sanctions screening
Implement ongoing CDD, transaction monitoring and risk assessment procedures
Implement Suspicious Matter Reporting (SMR), Threshold Transaction Reporting (TTR) and other AUSTRAC reporting procedures
Maintain compliant record-keeping practices for at least 7 years
Implement appropriate “tipping-off” controls and processes

Done for you.

AML Smart Guard’s AML as a Service enables full compliance with Tranche 2.

What you need to do by when

Key Dates and Activities

Date / Timing

Activity

31 March 2026 – 29 July 2026

Enrol with AUSTRAC as a reporting entity.

1 July 2026

AML/CTF obligations for newly regulated entities are underway. Firms should
have operationalised AML/CTF programs, governance frameworks, customer due
diligence, staff training and monitoring systems.

29 July 2026 (or within 14 days of enrolment)

Notify AUSTRAC of your appointed AMLCO.

Within 28 Days of First Providing a Designated Service

Appoint an AMLCO and notify AUSTRAC within 14 days of appointment

Ongoing Obligations

Perform ongoing customer due diligence, transaction monitoring, risk
assessments, suspicious matter reporting, staff training and AML/CTF
program updates.

Annual Obligations (1 July – 30 September each year for the prior financial year)

The AMLCO must report annually to the governing body on compliance
effectiveness, risk management and program performance.

See It In Action

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