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Your AML/CTF checklist: what you can start doing now to be ready in 2026

Published October 17, 2025

If you’re a lawyer, conveyancer, real estate agent or accountant, you’ve no doubt heard plenty of talk about Tranche 2 by now. You know it’s coming. You know it’ll mean new AML/CTF obligations. But the changes don’t come until next year.  So what exactly should you be doing right now to get ready?

The short answer: it’s time to move from awareness to action.

You don’t need to have every detail nailed down yet. AUSTRAC’s core guidance is due in October, with sector-specific guidance and “starter kits” arriving in late January 2026, but there’s still plenty you can do between now and then to make the transition next year a whole lot easier.

This checklist walks you through the steps you can take today to start preparing calmly, confidently, and without the last-minute stress.

Quick recap: where things are at with AML/CTF Tranche 2

Australia’s Tranche 2 AML/CTF reforms will extend AML/CTF obligations to new professional sectors including:

When the reforms take effect on 1 July 2026, these businesses will be required to:

The new AML/CTF Rules were officially released by AUSTRAC at the end of August 2025, marking the start of the countdown to implementation. Core guidance this month (October) will help explain what the new obligations mean in practice, while sector-specific guidance and “starter kits” will arrive in December to help each profession build their AML/CTF program.

Your Tranche 2 AML/CTF readiness checklist

1. Nominate your AML/CTF Compliance Officer

Every reporting entity must appoint a Compliance Officer responsible for implementing and maintaining the business’s AML/CTF program.

This person should be:

Their role will include overseeing your risk assessment, customer due diligence processes, reporting obligations, training, and independent reviews.

Now is a great time to identify who in your business is best placed to take on that responsibility, or, if you’re a sole trader or director, to start building your own knowledge.

Tip: The Compliance Officer role doesn’t need to be full-time. For many small businesses, it’s simply about nominating someone with the time, authority and attention to detail to manage compliance tasks.

2. Get informed with AUSTRAC’s four-part webinar series

AUSTRAC is currently running a free, four-part webinar series designed to help Tranche 2 industries understand their upcoming obligations. You can:

These sessions cover everything from an introduction to AUSTRAC right through to outsourcing arrangements. They’re presented by AUSTRAC experts and are an excellent first step for compliance officers, business owners and team leaders.

3. Attend an easyAML webinar

If AUSTRAC’s content tells you the what, easyAML webinars help you understand the how. Our webinars break down Tranche 2 in plain language, showing exactly what the new rules mean for your profession and how you can start preparing without the overwhelm. You’ll learn:

It’s the easiest way to get clarity, straight from compliance experts who specialise in small-to-medium Australian businesses just like yours.

Register for our next live session to cut through the noise and start preparing with confidence.

4. Review your current business processes

Take stock of what you already do around customer due diligence (CDD) and record-keeping, and start to identify where the gaps are. For example:

Documenting your current processes makes it much easier to build your AML/CTF program later. It gives you a chance to see what’s working, what’s missing from your processes, and what needs a little tightening before 2026.

Tip: If you’re currently using third-party providers for ID verification or data storage, check if they meet ISO 27001 security standards, and that your client data is stored in Australia.

5. Kick off some staff awareness training

Even before you have a formal program in place, it’s worth starting to build awareness among your team. Hold a short session explaining:

Starting early will not only help to bring your team along for the ride (and empower them), but it will also reduce confusion later when the new procedures and compliance become mandatory.

6. Check your data security and record-keeping systems

AUSTRAC expects businesses to retain records for at least seven years. This includes everything from customer identification and verification data to transaction details and staff training records.

Now’s the time to ensure your systems can handle that securely and efficiently:

If you’re already using a digital practice management, conveyancing or CRM platform, check whether it meets security and retention requirements or if you’ll need to adjust settings or policies before 2026.

7. Stay engaged through industry events

AML/CTF will be one of the biggest regulatory shifts to hit your industry in decades, and so there’s a growing calendar of events designed to help you prepare. Check in with your state or national association (AIC, REI, CPA, Law Society etc.) for local training and updates.

Here are some upcoming events that the easyAML is excited to be a part of:

These events are a great way to hear directly from AUSTRAC, regulators and technology partners about what’s coming and how to get ahead.

8. Keep learning and stay connected

The next six months will bring a lot of movement. With AUSTRAC’s core guidance and sector-specific starter kits expected to answer many of the “how” questions still on people’s minds. Until then, focus on education - be sure to read any updates that hit your inbox (hint: easyAML’s Readiness List will mean you won’t miss any news), subscribe to AUSTRAC and your professional body newsletters, and keep the conversation going in your business.

The more you understand now, the less overwhelmed you’ll feel later.

How to stay ahead on Tranche 2 AML readiness

The countdown to Tranche 2 is officially on, but preparation doesn’t have to be stressful. By taking these small, practical steps now, you’ll save yourself a lot of time, worry and cost in 2026.

Remember: the goal isn’t perfection, it’s progress.

Start now, and when July 2026 rolls around, your business will be ready: calm, confident, and compliant.

Reserve your place at our next easyAML webinar to get clear on what Tranche 2 means for you and learn exactly how to get your compliance right the first time.