AML/CTF Reform · Tranche 2

AUSTRAC Tranche 2

A concise guide for the ~80,000 Australian businesses newly regulated for anti-money-laundering.

What changed on 1 July

Australia's AML/CTF reforms took effect on 1 July 2026. About 80,000 businesses are regulated by AUSTRAC for the first time, lifting the regulated population from around 19,000 to close to 100,000. One obligation has a hard deadline this month.

Does this apply to you?

Regulated
  • Lawyers, conveyancers and legal services
  • Real estate: agents, buyer's agents, developers
  • Accountants and professional services
  • Trust and company service providers
  • Dealers in precious metals and stones (cash or crypto deals of $10,000 or more)
Not captured
  • Residential property management and leasing
  • Property leases of 30 years or less
  • General financial advice (captured only when directly delivering a listed service)
  • Transactions under court or tribunal orders

Check your services: austrac.gov.au/about-us/amlctf-reform/check-if-youll-be-regulated

What is actually at stake

Failing to enrol is a civil penalty, not a crime, but it accrues daily: up to $21,840 a day for companies and $4,368 for individuals via infringement notices (AML/CTF Act s51B). Maximums, not automatic fines. AUSTRAC has said early enforcement will target businesses that fail to enrol. The fix is enrolment.

How to enrol

By 29 July 2026, do exactly two things, in this order:

Appoint your AML/CTF compliance officer

It can be you. Their details go into the enrolment form, which is why this comes first.

Enrol via AUSTRAC Online

Create an account, open the Business menu, choose "Enrol a new business", complete and submit. The receipt only confirms submission. You are enrolled when AUSTRAC emails your account number. Start here: online.austrac.gov.au

Have ready before you open the form
  • Designated services you provide
  • ABN or ACN, legal and trading names
  • Key personnel: name, DOB, director ID, address
  • Beneficial owners (25% ownership or control)
  • Compliance officer (or a primary contact)
  • Staff numbers and turnover bands

After enrolment: August, without the panic

Keep evidence from day one
Evidence log for the AUSTRAC Tranche 2 enrolment
DateActionEvidence
11 JulConfirmed our services are capturedFile note and checker result
14 JulAppointed compliance officerEnrolment form copy and minute
14 JulEnrolled via AUSTRAC OnlineReceipt number and confirmation email

How polished your program is on day one matters less than being able to show what you did, and when. Records beat perfection.

Assess your money-laundering and terrorism-financing risk

Document the risks in your services, clients, channels and geographies. AUSTRAC publishes sector quick guides that turn this into a structured exercise rather than a blank page. Date the assessment, keep the working notes, and revisit it when your services change.

Free risk assessment template

Build the program: policies and customer due diligence

Write policies proportionate to your size and risk, then set up customer due diligence for new clients. Newly regulated firms start directly on the reformed due diligence rules, so build once, against the current requirements.

Free policy starter kit
Breathe. There is time to do this properly.

Your first independent evaluation is not due before 1 July 2029. Deadlines stagger by AUSTRAC account number. There is time to do this properly, just not time to skip enrolment.

Download this guide as PDF

Common questions

Does Tranche 2 apply to my business?

If you provide designated services in law, conveyancing, accounting, real estate, trust and company services, or deal in precious metals and stones with cash or crypto transactions of $10,000 or more, you are likely regulated from 1 July 2026. Check your services against AUSTRAC's official checker tool.

What has to be done by 29 July 2026?

Two things: appoint your AML/CTF compliance officer, then enrol via AUSTRAC Online. You are enrolled when AUSTRAC emails your account number, not when you submit the form.

What happens if I do not enrol in time?

Failing to enrol is a civil penalty, not a crime, and it accrues daily: up to $21,840 a day for companies and $4,368 for individuals via infringement notices under section 51B. These are maximums, not automatic fines. AUSTRAC has said early enforcement will target businesses that fail to enrol.

What is an AML/CTF program?

Two components: a risk assessment that identifies the money laundering, terrorism financing and proliferation financing risks in your services, customers, channels and countries, and AML/CTF policies that manage those risks. A senior manager approves both. In a small business, one person can hold every role.

Do my existing clients need due diligence on day one?

No. Customers you already had on 1 July 2026 need no initial due diligence until a suspicious matter report is triggered or their risk rises to medium or high. You still monitor them and keep their information current.

When is my first independent evaluation due?

Not before 1 July 2029. Deadlines stagger by AUSTRAC account number. There is time to build the program properly, just not time to skip enrolment.

Sources