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Key Dates

When does Tranche 2 come into effect? The legislation has passed, and the rules around Tranche 2 AML…


When does Tranche 2 come into effect?

The legislation has passed, and the rules around Tranche 2 AML compliance are being finalised. Implementation is set for 2026.

2025

2025

Sector-Specific Guidance Finalised

2026

2026

Choose AML Provider or Develop Internal Processes

Obligations Commence

DateWho It Affects
31 March 2026Current AUSTRAC entities and virtual asset service providers (VASPs)
1 July 2026New Tranche 2 professions (legal, accounting, real estate, conveyancing, etc.)

You don’t need to comply just yet, but now is the time to prepare. Setting up your systems early will make the transition smoother and reduce stress when these new rules hit. 

Smart businesses are preparing now. Are you one of them?

12 Months
8 Days

Your AML/CTF Obligations

Register with AUSTRAC

  • Complete AUSTRAC enrolment form
  • Provide business structure details
  • List designated services offered
  • Identify key personnel
  • Submit contact information
  • Appoint a compliance officer
  • Establish reporting channels
  • Set up AUSTRAC Online access

Risk Assessment

  • Conduct ML/TF/PF risk assessment
  • Identify customer risk factors
  • Assess product/service risks
  • Evaluate delivery channel risks
  • Consider geographic risks
  • Document risk methodology
  • Set risk appetite statement
  • Create risk matrix

AML/CTF Program

  • Develop written AML/CTF policies
  • Create CDD procedures
  • Design transaction monitoring
  • Build reporting processes
  • Establish record-keeping systems
  • Create governance structure
  • Document all procedures
  • Formally approve Program

Build a culture of compliance

  • Develop role-specific training modules
  • Conduct initial training for all staff
  • Implement new employee onboarding
  • Schedule annual refresher training
  • Create sector-specific risk training
  • Test understanding with assessments
  • Establish clear reporting lines
  • Define roles and responsibilities

Ongoing Compliance

  • Undertake Customer Due Diligence
  • Monitor customer transactions
  • Review customer risk ratings
  • Track regulatory changes
  • Conduct internal audits
  • Test compliance controls
  • Measure program effectiveness
  • Report to management

Meet Obligations

  • Submit SMRs within 72 hours
  • File TTRs for $10,000+ cash
  • Report IFTIs
  • Maintain 7-year records
  • Respond to AUSTRAC requests
  • Annual compliance reports
  • Board/management updates
  • Document all decisions

Make your compliance journey easy

Educate

  • Understand Tranche 2 regulatory implications
  • Identify if your business is captured
    under the AML Act

Examine

  • Conduct AML/CTF gap analysis
  • Risk assessment of business activities and customer profiles

Execute

  • Adopt an AML/CTF program
  • Leverage easyAML

Empower

  • Deliver tailored AML training for staff
  • Foster a culture of proactive compliance

Evaluate

  • Establish continuous monitoring and internal audit routines
  • Maintain compliance registers and reporting logs