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Tranche 2 is live. Australian businesses need to be AML compliant
Australia's AML/CTF Tranche 2 reforms are now in effect as of 1 July 2026. If your business provides designated services under AUSTRAC's expanded regime, including real estate, legal, and accounting services, you are now operating under new legal obligations.
This is not a drill, and it is not something you can defer. Providing a designated service without an AML/CTF program in place means penalties from AUSTRAC.
Here's what you need to know.
Who does Tranche 2 affect?
Tranche 2 significantly expands the range of businesses required to comply with Australia's AML/CTF framework. Where previously the regime focused on financial institutions and remittance providers, it now captures a much broader group of designated service providers, including:
- Real estate agents and agencies
- Legal professionals
- Accountants and bookkeepers
- Other businesses providing designated services under the expanded AUSTRAC framework
If you are unsure whether your business is captured, the short answer is: if you provide any of the services on AUSTRAC's designated services list, you are.
What are your obligations?
As a designated service provider, you are now required to:
Have an AML/CTF program in place
This is a documented, risk-based programme that outlines how your business identifies, manages, and mitigates money laundering and terrorism financing risks. We've developed a Tranche 2 starter kit based off AUSTRAC's guidance to help understand your obligations.
Train your team
Mandatory AML/CTF training is a legal requirement. Your staff need to understand their obligations and know how to identify suspicious activity.
The enrolment window is open now. AUSTRAC has encouraged businesses to enrol as early as possible.
Conduct ongoing customer due diligence
You must verify the identity of your clients and assess the risk they present to your business.
What happens if you do not comply?
AUSTRAC has made it clear that non-compliance is not treated lightly. Businesses that provide designated services without an AML/CTF program face significant civil and criminal penalties. The consequences are not theoretical. AUSTRAC has demonstrated a willingness to take action against businesses of all sizes.
How APLYiD helps
APLYiD is an end-to-end AML/CTF compliance platform built for exactly this. We work with small-to-medium real estate agencies, legal firms, and other professional services businesses across Australia to make compliance manageable, without the administrative burden.
Here's what you get with APLYiD:
Manage AML for every client and case from start to finish, all in one platform. No spreadsheets, no manual tracking.
Build your AML/CTF policy tailored to your business in minutes. Our policy builder guides you through the process so you end up with a compliant, documented programme ready for AUSTRAC.
Full access to comprehensive AML training for your team through our training platform. Meet your mandatory training obligations without sourcing external providers.
The law is in effect now.
If your business provides designated services and you do not yet have an AML/CTF program in place, now is the time to act. Every day without a programme is a day of exposure.
Start your 14-day free trial and get compliant today, or get in touch with our team and we will walk you through it.
