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Compliance
October 2, 20269 min read

Designated services decision tree for Tranche 2

Designated services are why a file is in or out. This tree sorts the common Tranche 2 scenarios. It does not copy the statute.

Quick answer

After 1 July 2026, ask three questions in order: are you doing this in business, is the work one of the newly regulated designated services, and who is the customer? The answer is a scenario, not a copy of the Act. If the file is awkward, stop and get advice.

People search “designated services austrac” because the statute table is the wrong shape for a Monday morning file. This page is a decision tree for Tranche 2 firms. It is general information, not legal advice, and it is not a substitute for the Act. Read AUSTRAC’s own pages for real estate designated services and professional designated services, and the obligations factsheet for tranche 2 reporting entities. The sector map on this site is /tranche-2.

Use this order, then stop

  1. In business, with an Australian link. A favour for a relative, or a matter with no connection to Australia, is a different question. Write down why you stopped.
  2. Name the service, not the job title. “Accountant”, “agent”, and “lawyer” are not designated services. Forming a company, brokering a sale, and assisting a transfer might be.
  3. Name the customer AUSTRAC’s page names. An agency that brokers a sale is often looking at both parties. A professional who assists one person is often looking at that person. Do not borrow the other industry’s customer.
  4. If two readings fit, get advice. A compliance adviser or your professional body is the right next step. Do not guess and collect passports to feel busy.

Scenarios firms actually have

A sorting aid. Confirm the row against AUSTRAC and your own facts.

SituationUsual readingGet advice if
Agency brokers the sale of a houseOften a real estate designated service, with both the seller and the buyer as customersYou only appraised or advertised and did not broker
Buyer’s agent brokers the purchaseBrokering for the buyer can still put both parties on the customer listYou searched and advised and never brokered
Developer sells apartments with no independent agentOften the “selling without an independent agent” service, customer the buyerAn independent agency is brokering, so you may be out of that item
Conveyancer or lawyer assists a transferOften a professional service, customer the person you assist, not automatically both partiesThe transfer is under a court or tribunal order
Lawyer drafts a will and nothing elseOften outside the professional items. Record why and stopThe will sits inside a transfer, a company sale, or client money
Accountant lodges a tax return or keeps the booksOften outside. Tax and bookkeeping alone are not a reason to verifyThe same engagement forms a company, sells the entity, or holds money to complete a deal
Accountant forms a company or helps sell the sharesOften inside the professional services. Treat it as in until advice says otherwiseYou only introduced a lawyer and did not assist the transaction
Jeweller sells goods for a large cash or virtual-asset sumDealers have their own items, often from a threshold. Read AUSTRAC before you assume a retail sale is in or outThe payment is split, or you are unsure which item applies

The longer industry trees already on this site stay where they are. Use designated services decision trees for the sector worksheets. Use this page when you need the post-1 July 2026 order of questions. Property customer questions that turn on who you act for are in who is the customer? and do buyer’s agents verify the seller?.

Three traps that make the tree lie

  • The job title. A practice can lodge tax returns all year and still provide a designated service the week it forms a company. The service on this file is the test. AML checks for accountants is the neighbouring workflow.
  • The long-standing client. Knowing someone is not the same as an exemption. Pre-commencement relief is narrow and has triggers. Read pre-commencement customers before you skip initial customer due diligence.
  • The court file. AUSTRAC’s professional services page carves out some transfers that exist only because a court or tribunal ordered them. That carve-out is easy to over-read. If the order is only part of the story, get advice before you treat the matter as out.

If the answer is yes

A “yes” means you are likely a reporting entity for that service. Enrolment, the written program, and the check are the next jobs. They are not this tree. AUSTRAC’s summary of obligations for tranche 2 entities is the official list. The factsheet says enrolment is due within 28 days of providing a designated service, which for many new services means 29 July 2026. Confirm the date on the factsheet before you diary it. The program you then write is covered in what Tranche 2 firms put in writing.

If the answer is no, write the reason on the file in a sentence a colleague can audit: which question failed, and what you would reopen if the work changes. “Not our problem” is not a reason.

Where FreeAML fits

FreeAML does not tell you that a service is designated. Your program does, with advice where the tree forks. When the answer is that a check is required, the firm suite is A$0 and verification is client-pays by email. Amounts are on FreeAML pricing.

Frequently Asked Questions

See which sectors the reforms name

Then price any check on its own. The firm suite is A$0 and verification is client-pays.

Open the Tranche 2 guide

Questions: team@freeaml.com.au