Tranche 2 AML in Australia: Key Dates & What You Need To Do Now

Published on 16 May 2025 at 22:28

As Tranche 2 of the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Act gains momentum in Australia, thousands of new businesses—especially law firms, accountants, and real estate agencies—will soon be subject to mandatory compliance obligations.

If you're in one of these sectors, here’s what you need to know about what’s changing, what’s required, and how to get ready.

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🗓️ Key Dates (Indicative Only)

  • May to July 2025: Targeted consultation on draft core guidance in working groups with industry associations and peak bodies 

  • August 2025: Finalization of AML/CTF Rules 

  • October 2025: Finalization of core guidance 

  • October to November 2025: Targeted consultation on tranche 2 sector-specific guidance in industry working groups  

  • December 2025: Finalization of tranche 2 sector-specific guidance 

    • 2026

    • 31 March 2026: Changes to obligations for current reporting entities and virtual assets service providers 

    • 1 July 2026: AML/CTF obligations commence for tranche 2 entities  

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      🔧 What’s Changing?

      Tranche 2 expands the reach of the AML/CTF Act to include designated non-financial businesses and professions (DNFBPs), such as:

      • Law firms & conveyancers

      • Accounting & bookkeeping practices

      • Real estate agents

      • Trust & company service providers

      ✅ What You Need To Do Now (and How We Can Help)

      👤 1. Appoint a Compliance Officer

      • Must be a suitably qualified person with appropriate seniority and access to resources.

      • Responsible for overseeing implementation and ongoing compliance.

      👉 We offer ready-to-use documents to assist you in recruiting the right person.

      🔍 2. Conduct an AML/CTF Risk Assessment

      • Assess the money laundering and terrorism financing (ML/TF) risks your business faces.

      • Consider:

        • Nature of your customers and services

        • Delivery channels (face-to-face, online)

        • Geographies involved

        • Size and complexity of your business

      👉 We provide risk assessment templates and guidance tailored to your business.

      📝 3. Develop an AML/CTF Program (Part A & B)

      Part A – Risk Management and Governance

      Includes:

      • Governance structure and responsibilities

      • Risk-based systems and controls

      • Employee training and awareness

      • Ongoing customer due diligence (OCDD)

      • Independent review procedures

      📗 Part B – Customer Due Diligence (CDD)

      Covers:

      • Identity verification procedures

      • Enhanced Due Diligence (EDD) for high-risk customers

      • Ongoing monitoring and record-keeping

      👉 Our document sets include fully editable suite of Microsoft documents for both Part A and Part B, aligned with AUSTRAC legislation.

      🔎 4. Enrol & Register with AUSTRAC

      • Enrol via the AUSTRAC Business Portal.

      • Some entities must also register (e.g. digital currency exchange providers, remittance service providers).

      👉 Done online.

      🧾 5. Implement Systems & Controls

      Put in place automated or manual systems to:

      • Verify customer identity

      • Monitor transactions

      • Detect and respond to suspicious activity

      • Record and retain data

      👉 Our Program covers all these functions. Covers CDD, EDD, PEP screening, beneficial ownership checks, monitoring transactions, and reporting suspicious activity and more.

      📚 6. Deliver Staff Training

      Train your team on What AML is and what their role and responsibilities are for:

      • Senior Managers

      • Compliance Team members (minimum Compliance Officer and his Manager)

      • Onboarding Staff

      👉 We provide training materials, attendance registers, and policy templates.

      🧾7. Reporting Obligations

      Ensure systems are in place to submit:

      • Suspicious Matter Reports (SMRs)

      • Threshold Transaction Reports (TTRs)

      • International Funds Transfer Instructions (IFTIs)

      • Annual Compliance Reports to AUSTRAC

      👉 Our program has all the Policies, Procedures, Forms and Registers to complete all these functions.

      📄 8. Maintain Records & Registers

      Keep records of:

      • Identity verification (7 years)

      • Transactions and monitoring

      • AML/CTF risk assessments

      • Training and audit logs

      👉 Get our full set of registers, record-keeping policies, and compliance tracking tools.

      📄9. Review & Audit the Program

      • Conduct periodic independent reviews of your AML/CTF Program.

      • Address any findings or recommendations.

      • Review your risk assessment and program regularly (at least annually or after major changes).

      👉 We have everything required to successfully prepare for audits and all the documentation to comply.

      🧭 10. Stay Informed

      The law is still evolving.
      👉 Join our mailing list to be notified of new templates, blog updates, and any law changes.

      Email us with your name and the product(s) you’re interested in to join our mailing list

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