From 1 July 2026, Australia’s anti-money laundering (AML) and counter-terrorism financing (CTF) regime will expand significantly under the so-called “Tranche 2” reforms. This expansion will bring thousands of businesses under AUSTRAC’s regulatory umbrella for the first time.
Who is Affected?
The new regulations will apply to a range of professionals and businesses collectively known as “designated non-financial businesses and professions” (DNFBPs):
- Real estate agents - Including property managers involved in buying, selling, or leasing real estate
- Lawyers and conveyancers - When performing certain activities such as property transactions, company formations, or trust administration
- Accountants - When providing specific services including tax advice, company formation, or trust services
- Precious metals and stones dealers - Businesses dealing in high-value precious metals or stones
- Trust and company service providers - Businesses forming companies, trusts, or providing registered office services
Key Obligations
1. AML/CTF Program
All affected businesses must develop, implement, and maintain an AML/CTF program. This program must be:
- Documented and approved by senior management
- Regularly reviewed and updated
- Appropriate to the nature, size, and complexity of your business
2. Customer Due Diligence (CDD)
You’ll need to verify the identity of your customers and understand the nature of their business relationships. This includes:
- Collecting identification documents
- Verifying beneficial ownership for entities
- Understanding the purpose and intended nature of the business relationship
3. Ongoing Customer Due Diligence
CDD is not a one-time exercise. You must:
- Monitor transactions and activities
- Keep customer information up-to-date
- Apply enhanced due diligence for higher-risk customers
4. Suspicious Matter Reporting
If you suspect a customer or transaction involves money laundering or terrorism financing, you must submit a Suspicious Matter Report (SMR) to AUSTRAC within specified timeframes.
5. Record Keeping
Detailed records must be maintained for at least 7 years, including:
- Customer identification records
- Transaction records
- AML/CTF program documentation
Preparing for Compliance
The time to start preparing is now. Here are the key steps:
- Assess your current operations - Understand which of your services fall under the new regulations
- Conduct a risk assessment - Identify the money laundering and terrorism financing risks specific to your business
- Develop your AML/CTF program - Create policies and procedures tailored to your risk profile
- Train your staff - Ensure everyone understands their obligations
- Implement systems - Consider technology solutions to streamline compliance
How AML Shield Can Help
AML Shield offers comprehensive solutions for Tranche 2 entities:
- Consultancy services to develop your AML/CTF program
- Training programs for your team
- Compliance platform for ongoing customer due diligence and reporting
Don’t wait until the last minute. Contact us today to start your compliance journey.