When regulatory tides shift, as they soon will for Australia’s Tranche 2 entities, even the most seasoned professionals can feel adrift. Real estate agents, legal practitioners, accountants, and others soon to be swept into the scope of AML/CTF obligations face not just new rules, but a transformation in the very fabric of their daily business. In moments like these, the guidance of a trusted financial adviser becomes more than helpful—it becomes a lifeline.
Turning Compliance Challenges into Opportunities for Growth and Trust
Picture a property developer who, until now, has focused on site visits and market analysis, now navigating a sea of compliance forms and risk assessments. Or an accountant, comfortable with numbers but new to the language of “due diligence” and “beneficial ownership.” For these professionals, the regulatory overhaul isn’t just another box to tick; it’s uncharted territory.
This is where the adviser’s value comes to life. Rather than simply reciting new requirements, the adviser becomes a patient guide—demystifying complex legislation, translating regulatory speak into clear, actionable steps, and helping clients map a plan forward. Through one-on-one conversations and tailored advice, advisers illuminate what Tranche 2 clients need to know. How to identify suspicious activity, implement robust customer identification procedures, and maintain the documentation that regulators will demand.
Supporting Tranche 2 Clients: Preparing Your Network for AML/CTF Responsibilities
As AUSTRAC’s 2025 AML/CTF reforms approach, a new cohort of businesses—referred to as Tranche 2 entities—are set to become subject to mandatory anti-money laundering and counter-terrorism financing rules. This group includes professionals across real estate, law, accounting, and virtual assets. Many of these may already be part of your client network or referral base.
At Australian Independent Compliance Solutions (AICS), we believe this regulatory shift is more than an obligation—it’s a strategic opportunity for AFSLs, ACLs, and advisers to offer greater value. By supporting your clients as they prepare for new compliance requirements, you reinforce their trust, deepen relationships, and play a vital part in protecting the financial system from criminal activity.
Key Date: 1 July 2026
From this date, Tranche 2 entities—such as real estate agents, buyer’s agents, property developers, lawyers, conveyancers, legal service providers, accountants, trust and company service providers, dealers in precious metals and stones, and Virtual Asset Service Providers (VASPs)—will need to comply with AML/CTF obligations.
What Tranche 2 Clients Need to Do
Enrol with AUSTRAC
- Deadline: Within 28 days of providing a designated service (typically by 29 July 2026)
- Ongoing: Update business details within 14 days of any changes
Develop an AML/CTF Program
Their program must include:
- A risk assessment for money laundering, terrorism financing, and proliferation financing
- Policies, systems, and controls tailored to their business
- Governance: Senior management approval and appointment of a Compliance Officer
Conduct Customer Due Diligence (CDD)
- Initial CDD: Identify and verify customers before providing services
- Ongoing CDD: Monitor transactions and update risk profiles
- Enhanced CDD: Required for high-risk customers
Meet Reporting Obligations
- Suspicious matters: Within 24 hours (terrorism) or 3 business days (other matters)
- Threshold transactions: A$10,000+ in physical currency within 10 business days
- Cross-border movements: Before customs or within 5 days of receipt
- Annual compliance report: AUSTRAC will notify when due
Maintain Records for 7 Years
- AML/CTF program documents
- CDD and transaction records
- Staff training logs and compliance activities
Penalties for Non-Compliance
Non-compliance with AUSTRAC’s AML/CTF obligations can result in significant penalties, including:
- Civil Penalties: Financial penalties can be substantial, with fines reaching up to millions of dollars depending on the severity and nature of the breach.
- Criminal Penalties: In cases of serious non-compliance, individuals and entities may face criminal charges, which can result in imprisonment.
- Reputational Damage: Beyond financial and legal repercussions, non-compliance can severely damage an entity’s reputation, resulting in a loss of client trust and business opportunities.
- Operational Disruptions: AUSTRAC may impose restrictions or conditions on the business operations of non-compliant entities, which can impact their ability to operate effectively.
How AICS Can Help You Add Value
At Australian Independent Compliance Solutions, we support AFSLs, ACLs, and advisers in extending their compliance expertise to Tranche 2 clients by:
- Providing tailored AML/CTF programs for real estate, legal, accounting, and crypto businesses
- Training teams on CDD, reporting, and governance
- Helping clients enrol with AUSTRAC and prepare for audits
- Offering white-label resources you can share with your network
- Acting as a referral partner for clients needing hands-on compliance support
A Strategic Opportunity
Helping your clients prepare for AML/CTF obligations isn’t just about compliance—it’s about building trust, demonstrating leadership, and strengthening your value proposition. By guiding Tranche 2 businesses through this transition, you’re not only helping them meet regulatory requirements—you’re helping them build more resilient, trustworthy, and future-ready operations.
Reference & Resources
AUSTRAC Tranche 2 Factsheet (PDF)
