What is Tranche 2 AML reform and when does it take effect for accountants?
Updated 23 May 2026
Quick answer
Tranche 2 reforms extend Australia's AML/CTF Act to accountants, lawyers, and real estate agents for the first time. Enrolment with AUSTRAC is required by 31 March 2026, and a compliant AML/CTF program must be in place by 31 July 2026.
The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024, which received Royal Assent on 29 November 2024, extends Australia's AML/CTF regime to cover designated non-financial businesses and professions (DNFBPs) for the first time.
What is Tranche 1 vs Tranche 2?
Tranche 1 of Australia's AML/CTF regime — in place since 2006 — covers financial institutions, casinos, remittance dealers, and bullion dealers. These businesses are already reporting entities with AUSTRAC obligations. Tranche 2 expands the net significantly, bringing in the professions that handle large client funds but have historically not been regulated under the AML/CTF Act.
Who is caught by Tranche 2?
- Accountants and tax agents — when providing bookkeeping, tax advice, company formation, or trust services
- Lawyers and conveyancers — when handling client money, property transactions, or company/trust creation
- Real estate agents — when facilitating the purchase or sale of real property on behalf of a client
- Trust and company service providers
- Dealers in precious metals and stones
Key compliance dates for accountants
- 31 March 2026: Deadline to enrol your business with AUSTRAC
- 31 July 2026: Your AML/CTF program (Part A and Part B) must be in place
- Ongoing: CDD on new clients, screening, transaction monitoring, and reporting obligations commence once your program is in place
Why Australia is acting now
The Financial Action Task Force (FATF), the global standard-setter for AML/CTF, has repeatedly identified Australia's failure to regulate DNFBPs as a significant gap. Australia's most recent FATF mutual evaluation cited this as a priority deficiency. The 2024 amendments bring Australia into alignment with FATF Recommendation 22, which requires all countries to regulate accountants and other gatekeepers.
How ClearAML helps
ClearAML is purpose-built for Tranche 2 compliance. The platform handles AUSTRAC enrolment guidance, AML/CTF program generation, client due diligence, PEP and sanctions screening, and SMR lodgement — covering all your obligations in one place.