Tranche 2 of the AML/CTF Act extends Australia's anti-money laundering (AML) and counter-terrorism financing (CTF) obligations to sectors that were previously unregulated. If you're a real estate agent, legal professional, accountant or other designated business, this applies to you.
Key dates
Date | What happens |
31 March 2026 | Enrolment with AUSTRAC opens. You must enrol to be able to comply. |
1 July 2026 | Full AML/CTF obligations commence. You must be compliant from this date. |
Who is affected?
Tranche 2 applies to Designated Non-Financial Businesses and Professions (DNFBPs), including:
Real estate agents and buyer's agents — for property sales only
Legal professionals (solicitors, barristers, conveyancers)
Property developers
Accountants providing certain designated services
Other designated professions
Rental and property management are exempt. Tranche 2 only applies to services involving the transfer of real property title (i.e., sales). If you handle both sales and property management, you only need to run AML checks on sales transactions.
What you're required to do
From 1 July 2026, affected businesses must:
Not Covered by APLYiD Workflow
Enrol with AUSTRAC (enrolment opens 31 March 2026)
Suspicious Matter Reporting (SMR) — report suspected money laundering or terrorism financing to AUSTRAC. There are forms on the AUSTRAC website that you are required to fill in the event you need to file an SMR.
Covered by APLYiD Workflow:
Develop an AML/CTF Program — documented policies and procedures for managing AML/CTF risk in your business. Contact support for guidance on generating your personalised policy.
Conduct Customer Due Diligence (CDD) — verify the identity of clients and assess their risk before providing a designated service. All of these requirements are achieved using APLYiD Wor
Ongoing monitoring — review higher-risk clients periodically; monitoring ends when the business relationship ends
Keep records for 7 years — all CDD records, transaction records, and your AML/CTF Program documentation
What is an AML/CTF Program?
An AML/CTF Program is a written document that describes how your business identifies and manages the risk of money laundering and terrorism financing. It is a standalone legal obligation — separate from actually conducting identity checks.
Your program must cover how you assess risk, what controls you have in place, how you train staff, and how you handle suspicious matters. AUSTRAC expects it to be documented and maintained before your obligations commence on 1 July 2026.
Developing your AML/CTF Program typically takes time, but we can help you. If you haven't started, now is the time. You can also speak with your industry association or reach out to a compliance specialist who can help.
How Workflow helps
Workflow handles the CDD, verification, risk assessment, and record-keeping requirements for your covered transactions:
Automated identity verification (KYC) and business verification (KYB)
Risk assessment templates aligned to AUSTRAC requirements
Ongoing monitoring alerts when a client review is due
Audit-ready case records with 7-year retention
Your AML/CTF Program (the policy document) that can be uploaded to your Workflow account. You can speak directly with us, your industry association or a compliance specialist for support developing this.
Action checklist
Confirm whether Tranche 2 applies to your business (it does for most real estate and legal practices)
Enrol with AUSTRAC from 31 March 2026
Develop your AML/CTF Program before 1 July 2026
Set up Workflow so you're ready to run checks on new transactions from 1 July 2026
Run identity checks and risk assessments on all relevant transactions from the commencement date
This article provides general information only and is not legal or regulatory advice. For guidance specific to your business, consult a legal professional or compliance specialist. You can also visit austrac.gov.au for the latest regulatory guidance.
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