On 1 July 2026, around 100,000 Australian businesses become reporting entities under the Anti-Money Laundering and Counter-Terrorism Financing Act for the first time. They include solicitors, conveyancers, accountants, bookkeepers, real estate agents, dealers in precious metals and stones, pubs and clubs operating gaming, and several adjacent financial services categories. Collectively this is known as Tranche 2.
The reform has been twenty years in the making. Australia is one of the last G20 economies to bring these professions into scope. The result is a compressed implementation window — most affected firms have between three and six months to design, document, train and operationalise an AML/CTF program before the regulator can begin supervisory engagement.
Who is actually captured
The Act doesn't capture professions wholesale — it captures the provision of specific designated services. A solicitor doing pure litigation is generally out of scope. The same solicitor handling client funds in a real estate settlement is in scope from 1 July 2026. The same accountant doing tax returns for individuals is generally out of scope. The same accountant forming a company on behalf of a client is in scope.
This matters because firms commonly have a mix of in-scope and out-of-scope work. Your first task as a principal is not to register with AUSTRAC — it is to scope your service mix and identify which services trigger which obligations.
What you must actually have in place
- AUSTRAC enrolment as a reporting entity before you provide a designated service.
- A documented AML/CTF program covering Part A (general) and Part B (customer identification).
- Customer due diligence on every client receiving a designated service, including beneficial ownership for non-individual clients.
- Ongoing monitoring of customers and transactions, with appropriate alerts and reviews.
- Suspicious matter reporting to AUSTRAC within statutory timeframes (typically 3 business days).
- Threshold transaction reporting where cash or equivalent transactions reach A$10,000.
- Annual training and a periodic independent review of your program.
- Record-keeping for seven years.
What the minimum viable program looks like
There is no statutory minimum. The Act and Rules are 'risk-based' — your obligations scale with the complexity and risk of your services and clients. A sole conveyancer running 50 settlements a year does not need the same program as a national property group running 50,000.
In practice the floor for an SME is: a written program, an electronic ID verification tool, a sanctions and PEP screening capability, a defensible audit trail, an annual training cycle, and a way to draft and submit SMRs and TTRs to AUSTRAC. The lowest-cost subscription tools in our directory cover all of this for between A$199 and A$650 per month.
Where to start
Take the free risk assessment — it walks you through the questions a provider would ask in their first call and produces a one-page profile of your obligations. Then get matched to two or three vetted providers and run a short evaluation against your specific service mix.