What Tranche 2 actually requires
Tranche 2 is the extension of Australia’s AML/CTF regime to the professions it left out in 2006. Accountants, law practices, conveyancers, real estate agencies and dealers in precious metals became reporting entities on 1 July 2026. These pages set out what the Act requires of them, obligation by obligation, with the sections each one rests on.
Why we wrote this
Most published guidance on Tranche 2 restates the press release. It names the captured sectors, gives the commencement date, and stops. The harder questions, the ones a firm hits in its first month, are covered thinly or not at all.
We built a compliance platform against these obligations, which meant resolving the ambiguities in code: what the deadline is when privilege is claimed, when a beneficial owner can be left out, what makes a cash transaction reportable. These pages are what we learned, with the section references so you can check us.
They are general information about the obligations, not legal advice, and duely is not approved, endorsed or certified by AUSTRAC. Where a page states something you intend to rely on, follow the citation to the Act or to the AUSTRAC guidance and read it there.
The obligations
One page per obligation. Each names the sector it matters most to, the sections of the Act it turns on, and the date its content was last checked.
- All sectors
Am I captured? Designated services under Tranche 2
A designated service is the trigger for Tranche 2. Provide one and you are a reporting entity from 1 July 2026, with obligations attached to that service.
AML/CTF Act sections
- s6
- All sectors
Enrolment with AUSTRAC: who, when and what you need
Firms providing a designated service must enrol with AUSTRAC before 1 July 2026. Enrolment opened 31 March 2026 and registers who you are and what you do.
- All sectors
What an AML/CTF program must contain
An AML/CTF program is a written ML/TF risk assessment plus the policies that act on it, approved by your governing body and kept current.
AML/CTF Act sections
- s26C
- s26D
- s26E
- s26F
- Law practices
Legal professional privilege and AML/CTF reporting
Privilege does not exempt a law practice from reporting. It decides which of three filing paths applies, and each path has a different deadline.
AML/CTF Act sections
- s5
- s41(2)(a)
- s41(2)(aa)
- s41(2A)
- s41(3)(aa)
- All sectors
Customer due diligence: what counts as verified
Establish who your customer is before you provide a designated service. Collecting a document is not verifying it, and how far you go scales with risk.
AML/CTF Act sections
- s28
- All sectors
Beneficial ownership: when you can stop digging
You must identify and verify every beneficial owner, anyone holding 25% or more or controlling the entity, before you provide a designated service.
AML/CTF Act sections
- s5
- All sectors
Suspicious matter reports: the three-day clock
You file a suspicious matter report within three business days of the suspicion forming, 24 hours for terrorism financing, or five for privileged grounds.
AML/CTF Act sections
- s41
- s41(2)(a)
- s41(2)(aa)
- s41(2)(b)
- s41(2A)
- All sectors
Threshold transaction reports and the $10,000 cash threshold
Any cash payment of $10,000 or more is reported to AUSTRAC in a threshold transaction report (TTR) within ten business days.
AML/CTF Act sections
- s43
- All sectors
Tipping-off after the 2024 amendments
Tipping off is an offence under s123: disclosing anything that could prejudice an investigation, even one not yet started, is criminal.
AML/CTF Act sections
- s123
- All sectors
Delayed initial CDD in real estate transactions
A buyer can be verified after the work begins, but no later than 28 days after exchange or 3 days before the initially agreed settlement day, whichever is earliest.
AML/CTF Act sections
- s28
- s29
- All sectors
Enhanced CDD: what triggers it and what it requires
Enhanced due diligence applies to PEPs, sanctions-affected customers, and other high-risk cases. It adds source of funds and source of wealth checks.
- All sectors
Appointing an AMLCO: eligibility and independence
An AMLCO must be an individual with seniority, independence and access to do the job, and the appointment is personal: the role carries accountability.
AML/CTF Act sections
- s26J(2)
- s26K
- s26L
- s26M(1)
- Accounting firms
Reliance on another reporting entity
You can rely on CDD another reporting entity has performed, but the liability stays with you. The arrangement must be written, and the records obtainable.
AML/CTF Act sections
- s37
- s38
- All sectors
Record-keeping: seven years of what, exactly
Keep every AML/CTF record for seven years, measured from a per-record anchor. The decision and its reasoning are records too, and must stay retrievable.
AML/CTF Act sections
- s107
- s108
- s111
- s114
- s116
- All sectors
Independent evaluation: scope and timing
Your AML/CTF program needs a regular independent evaluation, run by someone with no part in its design or operation, with findings to your governing body.
AML/CTF Act sections
- s26F(4)(f)
- s116
Also on this site
Knowing the obligation is the easy half
Take the 2-minute readiness assessment to see which of these obligations apply to your firm, or book a walkthrough and watch one matter run from scoping to a finished evidence pack.