What Tranche 2 actually requires
Tranche 2 is the extension of Australia’s AML/CTF regime to the professions it left out in 2006. Accountants, law practices, conveyancers, real estate agencies and dealers in precious stones and metals that provide the newly designated services have been reporting entities since 31 March 2026, and their AML/CTF program, customer due diligence, reporting and record-keeping obligations started on 1 July 2026. Bullion dealing was already designated. These pages set out what the Act requires of them, obligation by obligation, with the sections each one rests on.
Why we wrote this
Most published guidance on Tranche 2 restates the press release. It names the captured sectors, gives the commencement date, and stops. The harder questions, the ones a firm hits in its first month, are covered thinly or not at all.
We built a compliance platform against these obligations, which meant resolving the ambiguities in code: what the deadline is when privilege is claimed, when a beneficial owner can be left out, what makes a cash transaction reportable. These pages are what we learned, with the section references so you can check us.
They are general information about the obligations, not legal advice, and duely is not approved, endorsed or certified by AUSTRAC. Where a page states something you intend to rely on, follow the citation to the Act or to the AUSTRAC guidance and read it there.
The obligations
One page per obligation. Each names the sector it matters most to, the sections of the Act it turns on, and the date its content was last checked.
- All sectors
Am I captured? Designated services under Tranche 2
A designated service is the trigger for Tranche 2. Provide one and you are a reporting entity, with the main obligations applying from 1 July 2026.
AML/CTF Act sections
- s6
- All sectors
Enrolment with AUSTRAC: who, when and what you need
Enrol with AUSTRAC within 28 days of starting a designated service (s51B). Firms with only Tranche 2 services before 1 July 2026 had until 29 July 2026.
AML/CTF Act sections
- s51B
- s51E
- All sectors
What an AML/CTF program must contain
An AML/CTF program is a written ML/TF risk assessment plus the policies that act on it, approved by a senior manager and reviewed at least every 3 years.
AML/CTF Act sections
- s26C
- s26D
- s26E
- s26F
- s26P
- Law firms
Legal professional privilege and AML/CTF reporting
Privilege does not exempt a law practice from reporting. It decides which of three filing paths applies, and each path has a different deadline.
AML/CTF Act sections
- s5
- s41(2)(a)
- s41(2)(aa)
- s41(2A)
- s41(3)(aa)
- All sectors
Customer due diligence: what counts as verified
Establish who your customer is before you provide a designated service. Collecting a document is not verifying it, and how far you go scales with risk.
AML/CTF Act sections
- s28
- All sectors
Beneficial ownership: when you can stop digging
You must identify and verify every beneficial owner, anyone holding 25% or more or controlling the entity, before you provide a designated service.
AML/CTF Act sections
- s5
- All sectors
Suspicious matter reports: the three-day clock
A suspicious matter report is due three business days after the suspicion forms, or 24 hours for terrorism financing. One privilege case allows longer.
AML/CTF Act sections
- s41
- s41(2)(a)
- s41(2)(aa)
- s41(2)(b)
- s41(2A)
- All sectors
Threshold transaction reports and the $10,000 cash threshold
Any cash payment of $10,000 or more is reported to AUSTRAC in a threshold transaction report (TTR) within ten business days.
AML/CTF Act sections
- s43
- All sectors
Tipping-off after the 2024 amendments
Under s123 it is an offence to disclose that an SMR has been or must be given, or what it says, where that could prejudice an investigation.
AML/CTF Act sections
- s123
- All sectors
Delayed initial CDD in real estate transactions
A buyer can be verified after the work begins, but by the earlier of 28 days after exchange and 3 days before the initially agreed settlement day.
AML/CTF Act sections
- s28
- s29
- All sectors
Enhanced CDD: what triggers it and what it requires
Section 32 sets when enhanced due diligence applies: high risk, continuing after an SMR obligation, foreign PEPs, FATF-listed countries, unusual requests.
AML/CTF Act sections
- s32
- All sectors
Appointing an AMLCO: eligibility and independence
An AMLCO must be an individual with seniority, independence and access to do the job, and the appointment is personal: the role carries accountability.
AML/CTF Act sections
- s26J(2)
- s26K
- s26L
- s26M(1)
- Accounting firms
Reliance on another reporting entity
Rely on another regulated firm's CDD under a written agreement (s37A) or case by case (s38). If the conditions hold, the law treats the checks as yours.
AML/CTF Act sections
- s37
- s37A
- s37B
- s38
- All sectors
Record-keeping: seven years of what, exactly
Keep AML/CTF records for seven years from an anchor that depends on the record. Decisions and their reasoning are records too, kept retrievable.
AML/CTF Act sections
- s107
- s108
- s111
- s114
- s114A
- All sectors
Independent evaluation: scope and timing
Your AML/CTF program needs an evaluation at least every 3 years by someone independent of its design and operation, reported to your governing body.
AML/CTF Act sections
- s26F(4)(f)
- s116
- Real estate
Who is your customer in a property sale?
Broker a sale and the seller and the buyer are both your customers under Table 5. Each needs their own CDD, and they become customers at different times.
AML/CTF Act sections
- s 6(5A)
Also on this site
Knowing the obligation is the easy half
Take the 2-minute readiness assessment to see which of these obligations apply to your firm, or book a walkthrough and watch one engagement run from scoping to a finished evidence pack.