What is Tranche 2? Australia's AML reforms, in plain terms
Tranche 2 is the long-promised second stage of Australia's anti-money-laundering regime — the 2024 reforms that extended the AML/CTF Act beyond banks and casinos to the professions that had sat outside it for two decades: lawyers, accountants, real estate agents, conveyancers, trust and company service providers, and dealers in precious metals and stones. For those sectors, the obligations commenced on 1 July 2026.
If you run a business in one of them, 'Tranche 2' is really shorthand for 'you're now a reporting entity' — with an enrolment deadline, a compliance program to build and customer checks to run. Here's the whole picture, in plain terms.
Why it's called Tranche 2
Australia built its AML/CTF regime in stages. Tranche 1, in force since 2006, captured the obvious money-movers: banks, other financial services, remittance providers, gambling operators and bullion dealers. Tranche 2 was always meant to follow — extending the same framework to the 'gatekeeper' professions that international standards expect to be regulated. It just took the best part of twenty years to arrive.
The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 is the legislation that finally did it. For the newly regulated sectors, the operative obligations switched on from 1 July 2026, with AUSTRAC enrolment having opened on 31 March 2026.
Who Tranche 2 captures
Tranche 2 doesn't regulate professions by name — it regulates designated services, the specific activities listed in the AML/CTF Act. Provide one in the course of business, with a link to Australia, and you're in scope. The reforms added:
- Real estate — brokering the sale, purchase or transfer of real estate, including buyer's agents and developers selling their own stock (scope guide).
- Professional services — the gatekeeper work of lawyers, conveyancers and accountants: handling client money to advance deals, creating and restructuring companies and trusts, and nominee or registered-office arrangements.
- Dealers in precious metals and stones — transactions at or above the $10,000 threshold, which brings bullion dealers and jewellers into scope for qualifying deals.
- Expanded virtual asset services — a parallel expansion with its own timing and registration rules, largely separate from the professional sectors.
Because it's the service that counts and not the title, a business can be captured by one activity and not another — which is exactly where careful scoping pays off.
What Tranche 2 actually requires
Being in scope means, in sequence: enrol with AUSTRAC (a business profile, not an approval), appoint and notify a compliance officer, and stand up an AML/CTF program — a risk assessment, policies, customer due diligence, ongoing monitoring, record-keeping, and reporting of suspicious matters and threshold transactions. The enrolment deadline for businesses already providing designated services on 1 July 2026 is 29 July 2026; new entrants get 28 days from their first designated service.
The workload sounds heavier than it usually is for a small firm. The Government's own Regulation Impact Statement put the average ongoing compliance cost at about $23,250 a year — a figure worth knowing before a vendor quotes against your fear rather than your facts. For low-complexity businesses, AUSTRAC's free starter kit covers the foundational documents, and the paid-tooling decision can be made on facts.
The two things people get wrong
'Register' vs 'enrol'. Almost everyone calls it 'registering with AUSTRAC', but the Tranche 2 professions enrol — registration is a separate, stricter step for remittance and virtual asset providers. Same word in everyday speech, two different obligations in the Act.
'We're too small, or too clean, to be captured.' There's no minimum volume and no risk-based exemption from enrolment itself — one designated service is enough, however low-risk your clientele. The regime is about visibility and process, not suspicion. This is general information, not legal advice — where your services straddle a boundary, check AUSTRAC's designated services guidance and get specific advice.