Tranche 2 AML/CTF obligations start from 1 July 2026
Australia's AML/CTF regime is expanding to cover additional high-risk services provided by real estate professionals, lawyers, conveyancers, accountants, trust and company service providers, dealers in precious metals and stones, and certain virtual asset service providers.
Clarifyd helps Australian businesses prepare for client verification, AML/CTF risk assessment, and compliance-ready record keeping.
Obligations commence
1 July 2026
AML/CTF Amendment Bill 2024 — passed 29 Nov 2024
Timeline
Key Tranche 2 dates
29 Nov 2024
AML/CTF Amendment Bill 2024 passed Parliament.
31 Mar 2026
AUSTRAC enrolment opens for newly regulated Tranche 2 sectors.
1 Jul 2026
AML/CTF obligations start for Tranche 2 entities providing new designated services.
29 Jul 2026
Typical enrolment deadline for many newly regulated businesses providing services from 1 July 2026.
Dates should be checked against AUSTRAC guidance for your specific circumstances.
Affected sectors
Who may be affected by Tranche 2?
Tranche 2 obligations apply to certain designated services, not simply to every business in a profession. Depending on the services provided, affected sectors may include:
Real estate professionals
Includes agents, buyer's agents and property developers where they provide captured designated services.
Lawyers and conveyancers
Certain legal and conveyancing services may be captured where they involve higher-risk transaction types.
Accountants and advisers
Certain accounting and advisory services may be captured depending on the nature of the work.
Trust and company service providers
Services involving the creation, operation or management of companies, trusts or similar structures may be captured.
Dealers in precious metals and stones
Businesses dealing in high-value precious metals, stones or related products may be affected.
Certain virtual asset service providers
Some virtual asset services are also affected by the broader AML/CTF reforms.
Whether your business is captured depends on the specific designated services you provide. AUSTRAC recommends reviewing whether your services are regulated under the AML/CTF Act.
Talk to our team →Obligations
What Tranche 2 businesses need to prepare for
If your business provides captured designated services, you may need to build practical systems for customer due diligence, AML/CTF risk management, record keeping and reporting.
Enrol with AUSTRAC
Provide information about your business structure, services, key personnel and contact details. Enrolment opens 31 March 2026.
Develop an AML/CTF program
Create policies, systems and controls that reflect your business size, complexity and money laundering, terrorism financing and proliferation financing risk.
Conduct customer due diligence
Identify and verify customers and relevant associated persons using reliable and independent data sources.
Understand customer risk
Assess the risk associated with providing services to a customer, including customer type, transaction type, geography and other relevant risk indicators.
Screen for risk indicators
Consider sanctions, politically exposed persons, beneficial ownership and other risk indicators where relevant to the services you provide.
Keep compliance-ready records
Maintain clear records of identity checks, risk assessments, decisions and supporting documents for the required retention period.
Monitor and report where required
Apply ongoing customer due diligence and identify matters that may trigger suspicious matter reporting obligations.
Our products
How Clarifyd helps with Tranche 2 preparation
Clarifyd supports practical client onboarding and AML/CTF workflows by helping businesses verify clients, assess risk and maintain compliance-ready records.
ClariID
Verify individuals using secure digital ID checks and optional biometric verification, supporting your customer due diligence workflow.
Learn more →ClariCheck
Assess client AML/CTF risk and generate clear compliance-ready records to support your reporting and decision-making workflow.
Learn more →ClariScreen
Screen clients against sanctions, PEP registers and global watchlist sources in real time.
ScreeningChecklist
Tranche 2 readiness checklist
Use this checklist to start preparing your client onboarding and compliance workflow before obligations begin.
Tranche 2 readiness checklist — before 1 July 2026
Confirm whether your business provides captured designated services.
Identify which clients, matters or transactions may require customer due diligence.
Map your current client onboarding process.
Decide how you will verify individuals, entities and beneficial owners.
Prepare an AML/CTF risk assessment approach.
Determine how you will screen for sanctions, PEP and other risk indicators.
Set up record-keeping processes for identity checks, risk assessments and decisions.
Prepare staff training and define internal compliance responsibilities.
Plan for AUSTRAC enrolment from 31 March 2026 if your business is captured.
Review AUSTRAC guidance and seek professional advice where needed.
FAQs
Tranche 2 FAQs
Yes. The AML/CTF Amendment Bill 2024 passed Parliament on 29 November 2024. The reforms expand Australia's AML/CTF regime to cover additional high-risk services, with obligations for newly regulated sectors starting from 1 July 2026.
Yes. The AML/CTF Amendment Bill 2024 passed Parliament on 29 November 2024. The reforms expand Australia's AML/CTF regime to cover additional high-risk services, with obligations for newly regulated sectors starting from 1 July 2026.
For many newly regulated Tranche 2 entities, obligations start from 1 July 2026. AUSTRAC enrolment opens from 31 March 2026, and affected businesses generally need to enrol within 28 days of providing a designated service.
For many newly regulated Tranche 2 entities, obligations start from 1 July 2026. AUSTRAC enrolment opens from 31 March 2026, and affected businesses generally need to enrol within 28 days of providing a designated service.
Not automatically. Tranche 2 applies based on whether a business provides captured designated services, not simply because of the profession it operates in. Businesses should review AUSTRAC guidance and seek professional advice if they are unsure.
Not automatically. Tranche 2 applies based on whether a business provides captured designated services, not simply because of the profession it operates in. Businesses should review AUSTRAC guidance and seek professional advice if they are unsure.
Customer due diligence is the process of identifying and verifying customers and relevant associated persons, understanding the customer's risk profile, and keeping records that support compliance decisions.
Customer due diligence is the process of identifying and verifying customers and relevant associated persons, understanding the customer's risk profile, and keeping records that support compliance decisions.
Yes. Digital identity verification can support customer due diligence by helping businesses verify client identity using reliable and independent data. It should be used as part of a broader AML/CTF compliance workflow.
Yes. Digital identity verification can support customer due diligence by helping businesses verify client identity using reliable and independent data. It should be used as part of a broader AML/CTF compliance workflow.
Clarifyd supports client verification, AML/CTF risk assessment and compliance-ready record keeping. Compliance also depends on your business's AML/CTF program, policies, controls, staff training and ongoing obligations. We recommend reviewing AUSTRAC guidance and seeking professional advice.
Clarifyd supports client verification, AML/CTF risk assessment and compliance-ready record keeping. Compliance also depends on your business's AML/CTF program, policies, controls, staff training and ongoing obligations. We recommend reviewing AUSTRAC guidance and seeking professional advice.
More questions? View all FAQs or contact us.
General information only. This page provides general information only and does not constitute legal, regulatory or compliance advice. Whether your business is regulated under the AML/CTF regime depends on the specific services you provide and your circumstances. You should review AUSTRAC guidance and seek professional advice where needed.
Prepare your client verification workflow before July 2026
Clarifyd helps Australian businesses verify clients, assess AML/CTF risk and keep compliance-ready records as Tranche 2 obligations approach.