Tranche 2 AML/CTF Australia FAQs
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Do I need to start Tranche 2 AML compliance now?
Not technically. As of 2025, the rules are still being developed. Nothing is enforceable yet. However, Tranche 2 is confirmed and on its way. Starting now allows you to plan, budget and test your systems, rather than scrambling to meet deadlines under pressure closer to 2026.
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Will these changes definitely happen?
Yes, the Australian Government has committed to Tranche 2 as part of its promise to meet global anti-money laundering standards. Delays are possible during finalisation, but full implementation is no longer in question. It's not optional, it's on its way.
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What happens if I don’t comply with Tranche 2?
If your business ignores Tranche 2 obligations once they’re live, you could face regulatory action from AUSTRAC. Failing to comply could risk fines, investigations or client trust. The good news? Preparing as early as you can gives you control and peace of mind.
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How much will AML/CTF compliance cost?
We know cost matters, especially for small businesses. That’s why easyAML is built to be affordable and scalable. Here’s how Tranche 2 costs might look based on the Attorney General’s Department’s Impact Analysis estimates:
Business Turnover Upfront Cost Annual Cost Under $200,000 ~$4,040 ~$6,020 Over $200,000 ~$28,650 ~$33,230 -
Where can I learn more about Tranche 2 AML/CTF?
Head to AUSTRAC’s official website for updates, or contact the easyAML team to discuss your specific situation and next steps. We're here to help you navigate what's coming with clarity and confidence. Our support team handles the ongoing monitoring and updates, keeping compliance simple for your business.
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What’s the difference between Tranche 1 and Tranche 2?
Tranche 1 covered banks, casinos and money transfer services. Tranche 2 extends AML/CTF obligations to real estate agents, lawyers, accountants and other professional services. While Tranche 1 businesses have been complying for years, Tranche 2 brings these requirements to small and medium businesses for the first time.
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Can my small business be exempt from Tranche 2?
Most businesses in covered sectors will need to comply, regardless of size. While final exemptions aren't confirmed, AUSTRAC typically doesn't provide blanket small business exemptions for AML/CTF obligations. It's best to assume you'll need to comply and prepare accordingly rather than risk penalties later.
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How will AUSTRAC check if I'm compliant?
AUSTRAC checks compliance through things like document reviews, site visits and monitoring your reporting. If your policies, procedures, training records and systems are solid and your records are up to date, you’ll be in good shape. Proper documentation is essential in demonstrate your compliance efforts during any AUSTRAC review or audit.
Industry FAQs
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I'm a real estate agent. What does Tranche 2 mean for me?
Under Tranche 2, real estate agents will need to implement AML/CTF compliance measures including customer identification, record keeping and transaction monitoring. This means verifying client identities, maintaining detailed records and reporting suspicious activities to AUSTRAC. The exact requirements are still being finalised by the government.
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Do conveyancers need to comply with AML/CTF under Tranche 2?
Yes, conveyancers will be covered under Tranche 2 regulations. You'll need to establish customer identification procedures, maintain comprehensive records and implement transaction monitoring systems. As property transactions often involve large sums, conveyancers play a crucial role in preventing money laundering through real estate.
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What do lawyers need to do for AML compliance under Tranche 2?
Lawyers will need to implement customer due diligence, maintain detailed records and monitor transactions for suspicious activity. This includes verifying client identities, understanding the source of funds and reporting unusual transactions to AUSTRAC. Legal services involving property, company formation and financial transactions will be key focus areas.
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Are accountants and tax agents included in Tranche 2 reforms?
Yes, accountants and tax agents will be subject to Tranche 2 AML/CTF obligations. You'll need customer identification procedures, record-keeping systems and transaction monitoring capabilities. Services like company formation, trust establishment and high-value financial advice will require enhanced due diligence and reporting to AUSTRAC.
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How does Tranche 2 apply to virtual asset service providers (VASPs)?
VASPs, including cryptocurrency exchanges and wallet providers, will face comprehensive AML/CTF obligations under Tranche 2. This includes customer identification, transaction monitoring, record keeping and suspicious matter reporting. Given the high money laundering risks in virtual assets, VASPs will need robust compliance systems.
Still have questions?
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