Australia’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) regime is undergoing its most significant expansion in almost 20 years.

 

Known as the Tranche 2 AML/CTF reforms, these changes will bring many professional and transactional businesses into AUSTRAC regulation for the first time. From 1 July 2026, businesses that provide certain designated services will be required to comply with AML/CTF obligations — regardless of business size or revenue.

 

This article explains what Tranche 2 is, who it applies to, what obligations look like in practice, and how businesses can prepare early.

 

What Are the Tranche 2 AML/CTF Reforms?

 

Australia’s AML/CTF laws have historically focused on banks and financial institutions. Tranche 2 extends these laws to non-financial businesses that are often involved in high-value transactions, asset transfers, and complex structures.

 

The reforms are activity-based, not industry-based. This means businesses are regulated because of what they do, not simply because of their profession or job title.

 

Key dates to know

 

– 31 March 2026 – AUSTRAC enrolment opens for Tranche 2 entities

– 1 July 2026 – AML/CTF obligations commence

 

Key Sectors Impacted by Tranche 2

 

 

Diagram: Impacted Sectors

 

From 1 July 2026, AML/CTF obligations will apply where a person or firm provides a designated service in the course of carrying on their professional activities.

 

Key sectors within scope include:

 

– Real estate and property services (property sales, transfers, buyer’s agents)
– Law firms and legal services (transactions, conveyancing, trusts, client funds)
– Accounting and advisory firms (entity setup, restructures, execution support)
– Conveyancers and settlement agents
– Trust and company service providers (TCSPs)
– Dealers in precious metals, stones and products

 

Note: Regulation is activity-based. Obligations apply only where designated services are actually provided as part of the services delivered.

 

What Is a “Designated Service”?

 

A designated service is an activity that triggers AML/CTF obligations. Common examples under Tranche 2 include:

 

– Facilitating the purchase, sale or transfer of real estate
– Assisting with the sale or transfer of a business or company
– Creating or restructuring companies, trusts or partnerships
– Holding or controlling client money or assets during transactions
– Providing nominee directors, trustees or registered office services
– Selling shelf companies
– Supporting financing arrangements linked to entity structures

 

If your business performs any of these activities, you may be captured under the Tranche 2 reforms.

 

What Are the AML/CTF Obligations Under Tranche 2?

 

Once a business is captured, it must meet a set of ongoing AML/CTF obligations. These typically include:

 

– Enrolling with AUSTRAC as a reporting entity

– Conducting a money laundering and terrorism financing (ML/TF) risk assessment

– Developing and maintaining an AML/CTF Program

– Performing customer due diligence (CDD) and beneficial ownership checks

– Establishing suspicious matter reporting processes

– Maintaining compliant record-keeping systems

– Providing staff training and governance oversight

 

These obligations must be risk-based and proportionate, tailored to how the business actually operates.

 

Steps to AML Compliance

 

 
 
Why Early Preparation Matters

 

Although Tranche 2 obligations commence in July 2026, businesses that delay preparation often face:

 

– rushed and generic AML/CTF documentation
– disruption to onboarding and transaction processes
– staff confusion and compliance gaps
– higher remediation costs and regulatory risk

 

Early preparation allows businesses to:

– confirm capture with confidence
– design fit-for-purpose frameworks aligned to real workflows
– train staff effectively
– integrate AML/CTF requirements with minimal disruption

 

How Bravishi Advisory Can Help

 

At Bravishi Advisory, we support businesses through every stage of Tranche 2 AML/CTF readiness.
Our services include:

 

– Tranche 2 capture and service mapping
– ML/TF risk assessments aligned to AUSTRAC expectations
– Design and implementation of fit-for-purpose AML/CTF Programs
– Practical customer due diligence and reporting workflows
– Staff training and operational integration
– Ongoing readiness and compliance support

 

Our approach is practical, proportionate and grounded in how your business actually operates.

 

Speak With a Tranche 2 AML Specialist
 
If your business may provide designated services under the Tranche 2 reforms, now is the time to start planning.
 
Bravishi Advisory can help you assess your obligations and implement a clear, staged roadmap to AML/CTF compliance.
 
👉 Contact us to arrange a confidential, no-obligation discussion.