Your Complete Tranche 2
Compliance Guide
Everything you need to know about Australia's new AML/CTF obligations for real estate agents, lawyers, accountants, and trust service providers.
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Quick answers
The short version. The full FAQ is further down the page.
Who does Tranche 2 apply to in Australia?
Tranche 2 extends AML/CTF obligations to real estate agents, conveyancers, lawyers, accountants, trust and company service providers, and high-value dealers when they provide designated services.
When does Tranche 2 start?
Compliance obligations start on 1 July 2026. AUSTRAC enrolment opened on 31 March 2026. Businesses already providing designated services on day one need to enrol by 29 July 2026.
Do I need a monthly AML software subscription for Tranche 2?
No. FreeAML is pay-as-you-go: $0 per month, $20 for an individual check, and $40 for an entity check. Client-pays can bring your firm's out-of-pocket cost for that check to $0.
Where do I start a customer due diligence check?
Send a verification from the AML check page. Your client finishes the check, and you keep the outcome with the matter file.
Who Must Comply?
Tranche 2 applies to six industry sectors providing designated services in Australia.
Real Estate Agents
Brokering a sale, purchase or transfer. Ordinary leasing and property management are generally outside Tranche 2.
Conveyancers
Property settlement and transfer services
Lawyers
Trust accounts, property law, business transactions
Accountants
Trust services, entity formation, SMSF administration
Trust & Company Service Providers
Entity formation, trust administration, nominee services
High-Value Dealers
Precious metals, stones, jewellery ($10k+ transactions)
Related articles
Before you open AUSTRAC Online, gather the details on the AUSTRAC enrolment checklist and read what each enrolment question is asking. How you support the rest of the file without a monthly fee is in Tranche 2 customer due diligence without a monthly fee. If AUSTRAC asks who approved a risk rating, use the audit trail for that approval.
Sector guides: real estate agencies, accounting firms, conveyancers, precious metal dealers, and financial services. An AML check you can send today is how you run an AML check in Australia.
Your 7 Core Obligations
What you must do, deadlines, and how FreeAML makes it simple (and affordable).
1. AUSTRAC Enrolment
By 29 July 2026All Tranche 2 businesses must enrol with AUSTRAC via the Business Portal. You'll need your ABN/ACN, business structure details, beneficial ownership information, and designated services list.
FREE compliance program generator guides you through the exact information needed. No confusing forms.
2. AML/CTF Program
Before 1 July 2026Document and implement a written program that identifies ML/TF risks, describes your CDD and reporting processes, defines governance roles (Governing Body, Senior Manager, Compliance Officer), and includes an independent review schedule.
FREE AI-powered risk assessment (5 minutes) generates your complete program for your firm's file. Auto-updates when regulations change.
3. Customer Due Diligence (CDD)
Before every transactionVerify client identity using reliable, independent sources. For individuals: photo ID + biometric liveness. For entities: ASIC/ABN registry + beneficial owner identification (25%+ ownership). Screen all clients against PEP/sanctions lists.
Individual verification $20, entity $40. Includes ID verification, AML screening, UBO detection, and CDD reports for your firm's file. 60-second process. Client-pays option = $0 for you.
4. Ongoing Monitoring
ContinuousMonitor client transactions and behavior for suspicious activity. Update CDD when risk factors change. Review high-risk clients more frequently (PEPs, complex structures, unusual wealth).
FREE ongoing AML monitoring included with every verification. Automatic alerts when watchlist status changes.
5. AUSTRAC Reporting
Within strict timeframesSuspicious Matter Reports (SMRs): 3 business days (24hrs for terrorism). Threshold Transaction Reports (TTRs): Cash $10k+, report within 10 days. International Funds Transfer Instructions (IFTIs): 10 days. Annual Compliance Report: 1 Jan - 31 Mar each year.
FREE report templates pre-filled with your client data. Submit directly from dashboard. Automatic deadline reminders.
6. Staff Training
Initial + ongoingTrain all staff on AML/CTF obligations, ML/TF risks, consequences of non-compliance, and your business's specific policies. Training must be tailored (not generic), role-specific, and regularly updated.
Free 4-module training course with quizzes and certificates. Certificates issued in FreeAML use a FAML- ID. Your firm's training register records each member's progress and self-reported progress imported from a device. Admins and Compliance can include that register in the audit pack.
7. Record Keeping
7 years minimumMaintain comprehensive records of all CDD, transactions, reports, training, and compliance decisions. Records must be readily accessible for AUSTRAC audits.
You can download an audit pack for your firm: your program and risk assessment, CDD reports, AUSTRAC reports you prepared, the audit trail, the training register, sanctions checks, and annual compliance reports. Your firm still keeps the records the law requires.
Key Dates
Mark these deadlines in your calendar.
The Cost of Non-Compliance
Civil penalties are set in penalty units. AUSTRAC: consequences of not complying.
Criminal Prosecution
Civil Penalties
Infringement Notices
Professional Deregistration
Compliance is not optional
AUSTRAC actively monitors reporting entities and conducts audits. Non-compliance triggers investigations, enforcement actions, and public naming. With FreeAML, basic compliance costs $0/month. The cost of non-compliance could destroy your business.
Start Complying Today — For Free
No subscription. No setup fees. Verify your first client in 60 seconds. All compliance tools included free.
Frequently Asked Questions
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