Anti-Money Laundering and Counter Terrorism Financing (AML/CTF)

Tranche 2 AML/CTF 2026 Reforms

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From 1 July 2026, anti-money laundering and counter-terrorism financing (AML/CTF) obligations will extend to specific services commonly offered by businesses classified as Tranche 2 entities, including:

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• Real estate professionals (e.g. real estate agents, buyers’ agents, property developers)

• Dealers in precious metals, stones, and related products

• Lawyers

• Conveyancers

• Accountants

• Trust and company service providers​

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In addition, from 31 March 2026, a broader range of virtual asset-related services will also become subject to AML/CTF regulation.

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Summary of AML/CTF obligations for new industries:

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Businesses regulated by AUSTRAC must meet a range of core obligations, including:

• Enrolling and registering with AUSTRAC

• Designing and maintaining an AML/CTF program specific to their operations

• Conducting customer due diligence at onboarding and on an ongoing basis

• Reporting certain transactions and any suspicious matters to AUSTRAC

• Creating and retaining appropriate records

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The AML/CTF framework also recognises and protects information or documents subject to legal professional privilege.

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Understanding and complying with these obligations is critical to safeguarding your business from criminal exploitation and ensuring adherence to Australia’s AML/CTF legal requirements.

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Strict penalties will be enforced by AUSTRAC for non compliance.

 

Real Estate Agents

 

Does your business provide any real estate services, such as:

 

• Acting as an agent for the sale, purchase, or transfer of real estate on behalf of others (e.g., buyers' or sellers' agents)

• Selling or transferring property directly, without engaging an independent real estate agent (common among developers or auctioneers)

• Facilitating or executing property transactions for clients, such as through conveyancing services?

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Your business might be regulated under the Tranche 2 reforms to AML/CTF Act 2006. 

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Starting from 31 March 2026, additional services and entities will come under AUSTRAC’s regulatory oversight as a result of reforms to Australia’s anti-money laundering and counter-terrorism financing (AML/CTF) laws. These changes will also affect existing reporting entities.

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The updated AML/CTF regime is designed to strengthen Australia’s ability to prevent, detect, and respond to money laundering and terrorism financing, while aligning with international best practices and standards.

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Lawyers

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Does your business assist clients with any of the following activities:

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• Buying, selling, or transferring a legal arrangement or body corporate

• Securing equity or debt financing for a legal arrangement or body corporate

• Establishing or restructuring a legal arrangement or body corporate

• Selling or transferring a shelf company

• Appointing, or acting as, a company director, secretary, power of attorney, partner, trustee of an express trust, or similar role

• Appointing, or acting as, a nominee shareholder for a legal arrangement or body corporate

• Providing a registered office or principal place of business for a legal arrangement or body corporate

• Managing money, accounts, securities, virtual assets, or other property on behalf of a person to assist with planning or carrying out a transaction?

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Note: A "legal arrangement" includes an express trust, partnership, joint venture, unincorporated association, or any other form of legal structure.

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