If you've heard people mention "Tranche 2" and felt a bit lost, you're not alone. Here's what it actually means, in plain English — no legal jargon.
The short version
From 1 July 2026, a whole new group of Australian businesses has to start checking who their clients are and reporting anything suspicious to the government. This includes accountants, bookkeepers, lawyers, conveyancers, real estate agents, and a few other professions.
That's it. That's Tranche 2.
Wait — why is it called "Tranche 2"?
Back in 2006, Australia brought in anti-money laundering laws — but they only applied to banks, casinos, and a few other financial businesses. That first group was "Tranche 1."
Everyone always knew a second wave was coming, extending the same rules to more professions. That's "Tranche 2" — it's just been 20 years in the making.
Does this actually apply to me?
It depends on what you actually do for clients, not just your job title. You're likely in scope if you:
- Help set up or manage companies or trusts
- Handle client money in a trust account
- Help buy or sell property or businesses on someone's behalf
- Act as a director, trustee, or nominee for a client
If you're purely doing tax returns, BAS lodgement, or courtroom advocacy with nothing else, you're probably not captured. Most firms, though, do at least one thing on that list somewhere.
What do I actually have to do?
Four things, in plain terms:
- Enrol with AUSTRAC. A one-time registration. Deadline: 29 July 2026.
- Check your clients' identity. Basic ID verification before you do designated work for them.
- Write down your risk plan. A simple document explaining how you'll spot and handle risky clients (this is your "AML/CTF Program").
- Keep records and report anything suspicious. Hang onto your compliance records for 7 years, and tell AUSTRAC if something looks genuinely off.
What happens if I just... don't?
Honestly, the penalties are steep — into the tens of millions of dollars for serious, ongoing breaches. But AUSTRAC has said its early approach will focus on education, not gotchas. That said, enrolling by the deadline isn't optional, and it's the easiest box to tick, so there's no good reason to leave it to the last minute.
Is this actually a big job?
For a small practice, less than you'd think. A sole practitioner with a handful of clients can realistically enrol, verify a client, and generate a proper compliance program in a single afternoon with the right tool — it doesn't need to be a multi-week project or cost thousands in consultant fees.
What should I do right now?
Two things, honestly:
- Check whether you're actually in scope — this guide walks through it properly.
- If you are, enrol with AUSTRAC before 29 July 2026, then get your compliance program sorted. CompliDesk can do both in one sitting, starting free.
Ready to simplify your AML compliance?
CompliDesk guides lawyers, accountants, real estate agents, conveyancers, TCSPs, precious metals dealers and VASPs through every AUSTRAC obligation. Sign up free today.
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Related reading: How to enrol with AUSTRAC · Preparing your business for Tranche 2 · Choosing AML compliance software · Frequently asked questions