AML/CTF Tranche 2: Practical Guidance for Professional Services Firms
Australia’s AML/CTF regime is expanding, and from 1 July 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.
This page is a plain-English guide to help professional firms understand what is changing, how the rules may apply to their services, and what “proportionate, risk-based compliance” actually looks like in practice.
It’s designed to be a living resource. We’ll keep adding and updating sections as legislation, rules and AUSTRAC guidance continue to evolve. Where helpful, we’ll also link to official sources and tools so you can check the detail for your own circumstances.
This is not legal advice. It’s practical guidance to help you orient yourself, ask better questions, and start preparing in a sensible and structured way.
What is Tranche 2?
“Tranche 2” refers to the next phase of Australia’s anti-money laundering and counter-terrorism financing (AML/CTF) reforms. These reforms extend AML/CTF obligations beyond the financial sector to cover a range of professional services that can be used to facilitate certain types of financial or transactional activity.
In practical terms, this means that some services provided by professions such as accountants, lawyers, real estate professionals and other advisers may become regulated under the AML/CTF framework.
The key point is this: the rules do not apply simply because of your profession. They apply because of the services you provide. The AML/CTF regime works by regulating specific ‘designated services’, not job titles.
That distinction matters, because many firms will offer a mix of services — some that may be captured, and others that are not. Understanding Tranche 2 therefore starts with understanding what a designated service is, and whether any part of your work falls into that category.
The purpose of the Tranche 2 reforms is to reduce the risk that certain professional services can be misused for money laundering, terrorism financing or other serious financial crime, while still allowing firms to apply controls in a way that is proportionate to their size, risk profile and operating model.
In the sections below, we break this down in practical terms and focus on what it means for real-world professional practices — not just what the legislation says.
What is Tranche 2?
“Tranche 2” refers to the next phase of Australia’s anti-money laundering and counter-terrorism financing (AML/CTF) reforms. These reforms extend AML/CTF obligations beyond the financial sector to cover a range of professional services that can be used to facilitate certain types of financial or transactional activity.
In practical terms, this means that some services provided by professions such as accountants, lawyers, real estate professionals and other advisers may become regulated under the AML/CTF framework.
The key point is this: the rules do not apply simply because of your profession. They apply because of the services you provide. The AML/CTF regime works by regulating specific ‘designated services’, not job titles.
That distinction matters, because many firms will offer a mix of services — some that may be captured, and others that are not. Understanding Tranche 2 therefore starts with understanding what a designated service is, and whether any part of your work falls into that category.
The purpose of the Tranche 2 reforms is to reduce the risk that certain professional services can be misused for money laundering, terrorism financing or other serious financial crime, while still allowing firms to apply controls in a way that is proportionate to their size, risk profile and operating model.
In the sections below, we break this down in practical terms and focus on what it means for real-world professional practices — not just what the legislation says.
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