At Bravishi Advisory, we specialise in helping Tranche 2 businesses understand their obligations, confirm whether they are captured, and implement practical, fit-for-purpose AML/CTF compliance frameworks.
Australia’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) regime is undergoing a major expansion.
Under the Tranche 2 AML/CTF reforms, thousands of Australian businesses will become regulated by AUSTRAC for the first time. From 1 July 2026, businesses that provide certain designated services must comply with AML/CTF obligations, regardless of business size, turnover, or how small the regulated activity is within their operations.
At Bravishi Advisory, we specialise in helping Tranche 2 businesses understand their obligations, confirm whether they are captured, and implement practical, fit-for-purpose AML/CTF compliance frameworks.
The Tranche 2 reforms extend Australia’s AML/CTF laws beyond traditional financial services into a broader range of professional and transactional industries.
The reforms are activity-based, meaning a business is captured if it provides a designated service in the course of carrying on a business.
Key dates:
AUSTRAC enrolment opens: 31 March 2026
AML/CTF obligations commence: 1 July 2026
Early preparation is critical to avoid rushed compliance implementation and regulatory risk.
Tranche 2 will apply to businesses that provide designated services across industries including:
• Real estate agents and buyer’s agents
• Property developers involved in sales and transfers
• Businesses facilitating property transactions
• Law firms involved in conveyancing, transactions, trusts, or client funds
• Practices supporting company or ownership transfers
• Accountants and advisers assisting with company or trust structures
• Firms involved in business restructuring or transactional execution
• Conveyancing practices managing property transfers and settlements
• Businesses forming companies or trusts
• Registered office services, nominee arrangements, shelf companies
• Businesses trading in precious metals/stones above threshold levels
Importantly, AML/CTF obligations apply based on services delivered, not job titles or industry labels.
A designated service is an activity that triggers AML/CTF regulation. Common examples include:
Facilitating the purchase, sale or transfer of real estate
Assisting with buying or selling 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 Tranche 2.
Captured businesses will generally be required to:
Enrol with AUSTRAC as a reporting entity
Conduct a money laundering and terrorism financing (ML/TF) risk assessment
Develop and maintain a compliant AML/CTF Program
Implement customer due diligence (CDD) and beneficial ownership verification
Establish suspicious matter reporting and escalation procedures
Maintain compliant record-keeping systems
Train staff and ensure governance oversight
Prepare for AUSTRAC supervision and ongoing compliance expectations
Compliance must be proportionate, practical, and tailored to the risks of your business model.
• Determining whether your business provides designated services
• Mapping service lines against regulatory triggers
• Clarifying obligations across your operations
• ML/TF risk assessments aligned to AUSTRAC expectations
• Development of fit-for-purpose AML/CTF Programs
• Governance frameworks, roles and compliance oversight
• Practical customer onboarding and due diligence workflows
• Reporting, escalation and record-keeping procedures
• Staff training and implementation support
• Implementation roadmaps through to July 2026
• Compliance uplift and assurance preparation
• Ongoing support as AUSTRAC Rules and guidance evolve
Businesses that delay Tranche 2 compliance planning often face:
• Rushed, generic AML/CTF documentation
• Operational disruption to onboarding and transactions
• Increased remediation costs
• Higher regulatory risk and enforcement exposure
Early action enables businesses to:
• Confirm capture with confidence
• Implement scalable, practical frameworks
• Train staff effectively
• Demonstrate strong governance and AUSTRAC readiness
If your business operates in real estate, legal, accounting, conveyancing, TCSP or other professional services, now is the time to assess your Tranche 2 obligations.
Bravishi Advisory can provide a clear, staged roadmap to AML/CTF compliance — from capture assessment through to full operational implementation.
Contact us today to arrange a confidential, no-obligation discussion.
Download our Tranche 2 Readiness Checklist
Not sure if your business is captured? We can provide a short scoping assessment and practical readiness plan.
