AML/CTF Readiness and Tranche 2 Preparation

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Our Focus

Preparing early.

Building proportionate frameworks.

Avoiding the last minute rush.

Australia’s AML/CTF regime is expanding. From 2026 Tranche 2 reforms will bring new obligations for a range of professional services, including accountants, lawyers, real estate professionals and other designated service providers.

Ellevate Compliance is developing practical AML/CTF readiness support for firms who want to prepare early, understand what is coming and put appropriate governance foundations in place before compliance becomes urgent or disruptive.

Our AML/CTF work is governance led, risk based and fit for purpose.

Rather than a generic, one size fits all program, we focus on helping firms:

  • understand how AML/CTF obligatinos apply to their services

  • identify and assess AML/CTF risks in a practical way

  • design AML/CTF programs and controls aligned to risk

  • establish clear governance, oversight and accountability

  • prepare internal teams for future regualtory expectations

This approach supports sustainable compliance.

AML/CTF Support

Ellevate Compliance is in the process of building out its AML/CTF readiness offering in response to Tranche 2 reforms.

This work is focused on clarifying obligations, understanding regulatory expectations and shaping a governance led, risk based and fit for purpose approach to AML/CTF, ahead of formal commencement.

At this stage the focus is on:

  • understanding how Tranche 2 reforms may apply to different professional services

  • clarifying whether activities are likely to constitute designated service

  • exploring AML/CTF risk considerations relevant to different operating models

  • considering governance, oversight and accountability implications

  • monitoring legislative developments and upcoming AUSTRAC guidance

  • shaping future AML/CTF program structures and readiness support.

Who is this For?

This work is intended for small to mid-sized professional firms who:

  • will be captured by Tranche 2 AML/CTF reforms

  • want clarity well ahead of commencement dates

  • value proprtionate, practical compliance

  • do not want over engineered or unncessary systems

What you should be doing now

Tranche 2 AML/CTF reforms are progressing, and organisations are now able to enrol with AUSTRAC in preparation for upcoming obligations. With commencement expected from 1st July 2026, firms should be taking active steps now to ensure they are ready.

Key actions to focus on include:

  • Confirm whether you provide a designated service
    Operating in a tranche 2 industry does not automatically mean you provide a designated service. Checkout AUSTRAC’s Tool to see whether you do or not.

  • Subscribe to AUSTRAC’s Updates
    AUSTRAC are regularly publishing updates and guides as well as providing educational opportunities, keep up to date with what is happening.

  • Enrol with AUSTRAC before the 31st of March and prepare for commencement on 1st July 2026

  • Consider what resources you need now
    AML/CTF implementation requires clear accountability, oversight and resourcing, including people, systems and technology. Addressing these issues early will

Early preparation allows firms to move into compliance deliberately and confidently, rather than reacting under time pressure.

Ellevate compliance is available to support firms during this early preparation phase and will continue to update its AML/CTF offerings as regulatory guidance evolves.

How This is Taking Shape

AML/CTF readiness support is being developed progressively as Tranche 2 legislation and AUSTRAC guidance continue to evolve.

Rather than finalising tools or templates too early, Ellevate Compliance is taking a measured approach, focusing first on understanding regulatory intent, industry impacts and practical implementation considerations.

This staged approach is designed to support clarity and confidence, without forcing premature or overly complex solutions.

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