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 its governing body, 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.

Reference · Tranche 2

Tranche 2: the sectors the regime took in on 1 July 2026

Legal professionals, accountants, conveyancers, real estate professionals, and dealers in precious metals and stones. Who is actually covered, which table in section 6 decides it, and the six obligations that follow from providing a single designated service.

The legislation itself

The phrase is not in the Act
“Tranche 2” is industry shorthand, not a legal term. Search the legislation for it and you will find nothing — what you are looking for is section 6 and its tables of designated services.

The short answers

The second stage of a regime that started in 2006

Tranche 1 regulated banks and other financial institutions, casinos and remitters. Tranche 2 is the “gatekeeper” professions — the advisers and intermediaries who sit between money and the things it buys. FATF has recommended covering them since 2003; Australia did it on 1 July 2026.

Illustration: two groups of professionals separated by a gap, with a single gold post standing between them — Tranche 1 in 2006. Tranche 2, twenty years later

What is Tranche 2 in Australia?: Tranche 2 is the industry 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 does not appear in the Act. 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 its governing body, 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.

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.

Illustration: five professionals in a row holding a house, a document, keys, a balance and a gemstone, the gemstone picked out in gold — Five sectors — but it is the service in your hand that decides it

The five Tranche 2 sectors and the designated-service table that catches each
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)

The professional-services table is the one most people need to read line by line — all nine items of table 6 are quoted in full here.

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.

Illustration: six squares in a grid of two rows of three, the first picked out in gold, with a professional standing beside them — Enrolment happens once. The other five recur

Enrol with AUSTRAC

Within 28 days of first providing a designated service. Enrolment happens once; the obligations that follow recur.

Act, part 3A

Hold an AML/CTF program

A risk assessment plus policies, approved by your governing body, 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 context

Australia is late, not unusual

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.

Illustration: five professionals walking along one ground line at different points of the same journey, one picked out in gold — The same recommendation, five countries, twenty years apart

How comparable countries have regulated the gatekeeper professions
Country	Gatekeepers regulated	What prompted it	Where it stands
Australia	From 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 →Building the program →Customer due diligence →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 18 August 2026. If you spot an error, tell us at australia@getpostlabs.io.

Tranche 2, run as one workflow

Lex-AML helps organise what the regime asks of a newly regulated business — program preparation, customer onboarding, due diligence and audit-ready records.

Book a demo