Starts 1 July 2026

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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Tranche 2 Explained in 5 Minutes
31 Mar 2026
Enrolment Opens
1 Jul 2026
Compliance Starts
100,000 units
Civil penalty
~50,000
Businesses Affected

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.

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 2026

All 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.

How FreeAML helps:

FREE compliance program generator guides you through the exact information needed. No confusing forms.

$0

2. AML/CTF Program

Before 1 July 2026

Document 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.

How FreeAML helps:

FREE AI-powered risk assessment (5 minutes) generates your complete program for your firm's file. Auto-updates when regulations change.

$0

3. Customer Due Diligence (CDD)

Before every transaction

Verify 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.

How FreeAML helps:

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.

$20/person, $40/entity

4. Ongoing Monitoring

Continuous

Monitor client transactions and behavior for suspicious activity. Update CDD when risk factors change. Review high-risk clients more frequently (PEPs, complex structures, unusual wealth).

How FreeAML helps:

FREE ongoing AML monitoring included with every verification. Automatic alerts when watchlist status changes.

$0

5. AUSTRAC Reporting

Within strict timeframes

Suspicious 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.

How FreeAML helps:

FREE report templates pre-filled with your client data. Submit directly from dashboard. Automatic deadline reminders.

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6. Staff Training

Initial + ongoing

Train 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.

How FreeAML helps:

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.

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7. Record Keeping

7 years minimum

Maintain comprehensive records of all CDD, transactions, reports, training, and compliance decisions. Records must be readily accessible for AUSTRAC audits.

How FreeAML helps:

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.

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Key Dates

Mark these deadlines in your calendar.

31 March 2026
AUSTRAC enrolment portal opens
1 July 2026
Tranche 2 commences — all obligations apply
29 July 2026
Enrolment deadline (if providing services on Day 1)
1 Jan 2027
First Annual Compliance Report due (1 Jan - 31 Mar)
Non-Compliance Penalties

The Cost of Non-Compliance

Civil penalties are set in penalty units. AUSTRAC: consequences of not complying.

Criminal Prosecution

Up to 2 years imprisonment
Individuals

Civil Penalties

100,000 penalty units
Up to, for a body corporate. Up to 20,000 penalty units for other persons.

Infringement Notices

May be issued
For some AML/CTF breaches

Professional Deregistration

Loss of license
Industry-specific

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

Want these duties as steps you can follow? Open full AML compliance in 6 steps.