AUSTRAC Tranche 2: What Every Accountant, Lawyer, and Agent Needs to Know

If you're an accountant, lawyer, real estate agent, conveyancer, or precious metals dealer in Australia, you're about to encounter a major regulatory shift. Here's what you need to know.

What is Tranche 2?

In October 2024, Australia passed the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024, commonly called "Tranche 2." This extends Australia's existing AML/CTF framework to a new set of professions that were previously exempt.

Since 2006, Australia's AML/CTF laws have applied to financial institutions, banks, casinos, and remittance providers (Tranche 1). For nearly 20 years, the professional services sector operated outside these regulations. That's now changing.

Who is affected?

Tranche 2 affects approximately 100,000 Australian businesses across five professions:

• Accountants and tax agents — including BAS agents, auditors, and financial advisors providing certain services
• Lawyers and solicitors — when acting in certain transactional matters (property, company formation, financial arrangements)
• Real estate agents — involved in buying, selling, or leasing property
• Conveyancers — handling property transfers and settlements
• Precious metals and stones dealers — when transactions exceed the designated threshold

What are the obligations?

As a "reporting entity" under the AML/CTF Act, you must:

1. Enrol with AUSTRAC — Registration opens March 31, 2026. You must enrol before providing designated services.
2. Develop an AML/CTF program — A written program with Part A (customer identification, risk management, transaction monitoring) and Part B (employee due diligence).
3. Conduct Customer Due Diligence (CDD) — Verify client identity before providing services. Enhanced CDD applies to high-risk clients.
4. Report suspicious matters — Lodge Suspicious Matter Reports (SMRs) with AUSTRAC when you form a suspicion of money laundering or terrorism financing.
5. Report threshold transactions — Cash transactions of $10,000 or more must be reported via Threshold Transaction Reports (TTRs).
6. Keep records — Maintain records for 7 years, including CDD documentation, transaction records, and compliance evidence.

Key dates

How much will compliance cost?

The government's own Regulation Impact Statement (RIS) provides cost estimates:

• Average setup cost: $28,650 per entity
• Average ongoing cost: $23,250 per year
• Total 10-year cost (all entities): $4.4 billion

These figures assume manual compliance processes — hiring consultants, building spreadsheets, and dedicating staff time. Software like ComplyAU significantly reduces these costs, with plans starting at $79/month ($948/year).

What are the penalties for non-compliance?

AUSTRAC has significant enforcement powers. Penalties include:

• Civil penalties: Up to $22.2 million per contravention for corporations
• Criminal penalties: Up to 2 years imprisonment for certain offences (e.g., tipping off)
• Enforceable undertakings: Legally binding agreements to remedy compliance failures
• Remedial directions: AUSTRAC can direct you to fix specific compliance issues

AUSTRAC has a track record of enforcement. In 2018, they imposed a $1.3 billion penalty on Commonwealth Bank and a $1.3 billion penalty on Crown Resorts in 2023 (subsequently reduced). While these were large financial institutions, AUSTRAC has made clear they intend to enforce compliance across all reporting entities.

What should you do right now?

If you're in one of the affected professions, start preparing now:

1. Understand your obligations — Read our profession-specific guides for accountants, lawyers, RE agents, and conveyancers.
2. Download the compliance calendar — Our free calendar lists every key date from now to December 2026.
3. Start building your AML/CTF program — Don't wait until June. The program takes time to develop and implement.
4. Train your staff — Everyone in your firm needs to understand AML/CTF basics before July 1.
5. Choose your compliance tools — Whether it's ComplyAU or something else, get your software set up well before the deadline.

How ComplyAU helps

ComplyAU is an compliance platform built specifically for Tranche 2 entities. It handles:

• AI-generated AML/CTF programs tailored to your profession
• Guided CDD and enhanced CDD workflows
• SMR, TTR, and IFTI filing
• Staff training with completion tracking
• Risk assessment at client and enterprise level
• 7-year encrypted record keeping with immutable audit logs

Plans start at $79/month. Join the waitlist for early access and a 14-day free trial.