— days remaining until 1st July 2026 Deadline

Tranche 2 AML/CTF Reforms – Are You Ready for 1 July 2026?

From 1 July 2026, Australia’s Tranche 2 AML/CTF reforms will significantly expand the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) regime to include professional service providers, including accounting, tax and advisory firms.

A large number of firms will become “reporting entities” under the AML/CTF Act and will be required to implement comprehensive compliance and reporting frameworks.

Penalties for non-compliance are severe.

Your obligations

Key AML/CTF Requirements before 1 July 2026

Firms that provide one or more “designated services” under the AML/CTF Act should prepare for thefollowing 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 commerce. Firms should
have AML/CTF programs, governance frameworks, customer due
diligence, staff training and monitoring systems operational by this date.

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.

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