Enrol with AUSTRAC
Within 28 days of first providing a designated service. Enrolment happens once; the obligations that follow recur.
Act, part 3A
Reference · Tranche 2
AML/CTF Tranche 2: who is covered and what to do now
From 1 July 2026, certain services provided by legal, accounting, conveyancing, real estate and precious-metals businesses are within Australia’s AML/CTF regime. Scope follows the designated service — then the program, CDD, training, reporting and record-keeping obligations follow.
The phrase is not in the Act
“Tranche 2” is shorthand, not a legal term. It appears nowhere in the AML/CTF Act 2006 or in the Amendment Act 2024 — we searched both in full. It appears 12 times in the Bill’s Explanatory Memorandum, which calls these sectors “Designated Non-Financial Businesses and Professions (DNFBPs) or tranche two in the Australian context”, and at paragraph 15 sends you where the obligations actually live: “Schedule 3 of the Bill would expand the list of designated services in section 6 of the AML/CTF Act”. So does this page.
What to do now
Three things are true today
- The obligations commenced on 1 July 2026.
- They reach five sectors — legal, accounting, conveyancing, real estate and dealers in precious metals and stones — through the services in section 6, not the profession.
- AUSTRAC is now enforcing enrolment. On 28 August 2026 it began issuing section 167 notices to real estate agents, accountants, lawyers and jewellers that appear to provide designated services and have not enrolled. The notices require the business to provide information so AUSTRAC can determine whether it is regulated. Its CEO’s words: “The time for preparation has passed.”
The order to do things in
Six steps. This page owns the order; each step links to the page that owns the detail, so nothing here is a summary of something said better elsewhere.
- 01
Work out whether any service you provide is a designated service under section 6. Start from the service, not the profession.
- 02
Enrol with AUSTRAC within 28 days of first providing one. Enrolment has been open in AUSTRAC Online since 31 March 2026; since 28 August 2026 AUSTRAC has been issuing section 167 notices to businesses that appear to provide designated services and have not enrolled.
- 03
Customise and approve the three program documents — the risk assessment, the policies and the process — sized to your business.
- 04
Set up the customer workflow and the records: what happens when a customer arrives, what is verified, what is decided, and where the evidence is kept.
The customer workflow →What customer due diligence requires →
- 05
Train the people who touch any of it. Training is written into the obligation, not an optional extra.
- 06
Keep it current: review the program when services, risks, staff or AUSTRAC guidance change, and keep the records that show you did.
What a section 167 notice is
Section 167 of the Act lets the AUSTRAC CEO require a person to give information or produce documents. The notices announced on 28 August 2026 are being sent to businesses AUSTRAC believes may be providing designated services without having enrolled; answering one is not optional. AUSTRAC’s stated position is that its Contact Centre exists to help businesses comply, and that contacting it “isn’t a red flag” — the businesses it is targeting are the ones that have not engaged at all.
Enrolment is one step in becoming operational under the regime; it is not the AML/CTF program itself. The risk assessment, policies and customer-level controls must be in place when the Act requires them, whether or not a notice has arrived.
AUSTRAC, “AUSTRAC issues notices to non-enrolled businesses”, 28 August 2026 · checked 12 September 2026
Who is covered
Five sectors, three tables, one test
The sector label is a convenience. What decides coverage is whether you provide a service named in one of section 6’s tables — which is why a firm can be caught for one matter and not another, and why two practices with the same qualification can land on opposite sides of the line.
| Sector | Caught by | Typically in scope for |
|---|---|---|
| Legal professionals | Table 6, items 1–9 | You may be in scope where you provide designated professional services — for example assisting with the buying or selling of real estate, managing client money or assets, or helping set up companies or trusts. |
| Accountants | Table 6, items 1–6 | You may be in scope where you provide designated professional services — for example managing client money, assets or accounts, or assisting with the creation or restructuring of companies or trusts. |
| Conveyancers | Table 6, items 1, 2 and 3 | You may be in scope where you assist clients with the transfer of real estate and related settlement services. |
| Real estate professionals | Table 5, items 1–2 | You may be in scope where you act as an agent in the buying, selling or transfer of real estate, or provide related designated services. |
| Dealers in precious metals & stones | Table 2, item 2 | You may be in scope where you buy or sell precious metals, precious stones or precious products above the relevant thresholds. |
AML/CTF Act 2006 (Cth), s 6 — Compilation No. 62 (C2026C00274)
This table maps sectors to tables; it is not the list of services. The list — every table of section 6, quoted, with the names AUSTRAC Online uses for each service — is on its own page, and the nine professional services are read line by line on the Table 6 page.
What follows
Six obligations, from one designated service
Cross the line once and the Act’s general machinery applies. Enrolment happens once; everything after it recurs for as long as you provide the service.
Hold an AML/CTF program
A risk assessment plus AML/CTF policies, approved by a senior manager, sized to the nature, size and complexity of your business.
Act, ss 26C and 26F
Appoint a compliance officer
One named individual at management level, with the authority, independence and resources to do the job. 28 days to fill or refill the role.
Act, ss 26J–26M
Do customer due diligence
Before you provide the service, and continuing for as long as the relationship lasts — with enhanced measures where risk is higher.
Act, part 2
Report
Suspicious matters when a suspicion is formed, and threshold transaction reports for cash at or above $10,000.
Act, part 3
Keep records
Seven years, covering the identification you did, the decisions you made, and the reasons for them.
Act, part 10
None of this scales with your ambition — it scales with the nature, size and complexity of your business and the risks it actually faces. A three-person conveyancing practice and a national firm owe the same obligations in kind, and nothing like the same amount of work.
The history
Why Australia calls this Tranche 2
Australia’s original AML/CTF regime focused on financial institutions, casinos and remitters. The 2026 expansion brought specified “gatekeeper” services provided by legal, accounting, conveyancing, real-estate and precious-metals businesses into the regime.
What is Tranche 2 in Australia?
Tranche 2 is the shorthand for the sectors brought into Australia’s AML/CTF regime by the Amendment Act 2024 — legal professionals, accountants, conveyancers, real estate professionals, and dealers in precious metals and stones. The phrase appears nowhere in the AML/CTF Act 2006 or the Amendment Act 2024; it appears 12 times in the Bill’s Explanatory Memorandum, which describes these sectors as “Designated Non-Financial Businesses and Professions (DNFBPs) or tranche two in the Australian context”. Tranche 1, in 2006, covered banks and other financial institutions, casinos and remitters.
When did Tranche 2 start?
Obligations for the newly regulated sectors commenced on 1 July 2026. A business must enrol with AUSTRAC within 28 days of first providing a designated service.
Who is covered by Tranche 2?
Coverage follows services, not professions. A business is a reporting entity because it provides a service named in section 6 of the Act — table 6 for professional services, table 5 for real estate, table 2 for dealers in precious metals and stones. Two firms with the same qualification can land on opposite sides of that line.
What does a Tranche 2 business have to do?
Enrol with AUSTRAC, hold an AML/CTF program with a risk assessment and policies approved by a senior manager, appoint a compliance officer, carry out customer due diligence before providing the service and on an ongoing basis, report suspicious matters and threshold transactions, and keep records for seven years.
Why is it called Tranche 2?
Because it is the second stage of implementing the FATF recommendations in Australia. The first stage, in 2006, regulated financial institutions, casinos and remitters. The second stage — the "gatekeeper" professions FATF has recommended covering since 2003 — took a further twenty years and a critical 2015 mutual evaluation to arrive.
International context — how comparable countries approached gatekeeper regulation
FATF’s 2015 mutual evaluation of Australia found the gatekeeper professions unregulated, and said so. It took until the Amendment Act 2024 to close that gap. The comparison worth knowing is that the country most often invoked as a reason not to act — the United States — still has not.
| Country | Gatekeepers regulated | What prompted it | Where it stands |
|---|---|---|---|
| Australia | Since 1 July 2026 | FATF mutual evaluation, 2015 | Amendment Act passed November 2024 |
| United Kingdom | Since 2007 | EU directives and FATF | Consolidating 23 supervisors into the FCA |
| Canada | Partially, and expanding | FATF 2016 evaluation and the Cullen Commission | Penalties substantially increased |
| United States | Partially — lawyers and real estate agents still largely outside | FATF 2016 evaluation | Rated non-compliant on Recommendations 22, 23 and 28 |
| Philippines | Partially | Grey-listed in 2021 | Working to exit the grey list |
FATF mutual evaluation reports and national regulator publications
Where to go from here
Am I caught? Table 6 in full →What an AML/CTF program requires →AUSTRAC program starter kits →Customer due diligence →New to AML/CTF? Start the free Foundations module →AML/CTF training →The legislation →
This content is general information only. It is not legal, financial or compliance advice. Organisations should check AUSTRAC guidance, legislation, their own AML/CTF Program and professional advice where needed. Published by GetPost Labs Pty Ltd, a technology company building compliance software. Last checked 12 September 2026. If you spot an error, tell us at australia@getpostlabs.io.
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