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AML Tranche 2 Explained: What You Need to Know

  • Writer: Elevated Magazines
    Elevated Magazines
  • Sep 2, 2025
  • 9 min read

Key Highlights

  • Australia’s anti-money laundering laws are expanding under the AML Tranche 2 reforms.

  • These changes will impact Designated Non-Financial Businesses and Professions (DNFBPs), including lawyers, accountants, real estate agents, and conveyancers.

  • Affected businesses will become reporting entities and must register with AUSTRAC.

  • New obligations include developing a CTF program, conducting customer due diligence, and reporting suspicious activity.

  • The goal is to strengthen Australia’s defences against money laundering and terrorism financing.

  • Compliance with these new regulations is mandatory, with significant penalties for failure.


Introduction

Australia is getting ready to make big changes to its anti-money laundering and counter-terrorism financing rules. These new rules are called AML Tranche 2. They will now cover more types of jobs and businesses. The main goal is to make the country’s money system stronger and safer from money laundering and terrorism financing. These changes will affect many businesses. They will have to follow new rules to help stop financial crime and the funding of terrorism. It is important for everyone in these jobs to know what the new rules are and what they need to do to follow them.


Understanding AML Tranche 2 in Australia

So, what do these reforms mean for people and groups? The AML Tranche 2 changes are the next big part in making Australia’s CTF regime wider. These updates will put more non-financial jobs and businesses under the watch of the Australian Transaction Reports and Analysis Centre (AUSTRAC), which is the country’s main group for making sense of money moves.


This rule builds on laws that are already there, like the Financial Transaction Reports Act. The plan is to fix some holes in the rules, because some criminals have used these gaps to get away with breaking the law. Many businesses will now need to deal with CTF obligations for the first time. They will need to work with AUSTRAC and learn about new steps to follow under the CTF regime.


Overview of Anti-Money Laundering Reforms

The push to make these changes is because there is a need to keep Australia safe from criminal activity. For a long time, some jobs that deal with a lot of money and assets have not been covered by AML/CTF laws. This has made it easy for money laundering to happen.


Australia is now bringing its laws up to international standards. The Financial Action Task Force (FATF) is a group that looks at money laundering and terrorist financing all over the world. The group has said that countries need to make rules to regulate these services. By putting in Tranche 2, Australia’s reformed laws help its image overseas and make it known as a safe country for doing business. It will also make it up-to-date with what other developed countries are doing.


With these changes, it will be much harder for criminals to use real professional services to hide the proceeds of crime. Financial institutions have already had to follow these rules for a long time. Now, by making other key groups follow them too, the government is closing big gaps in the law. These steps are a strong part of the fight against money laundering.


The Significance of Tranche 2 for Local Businesses

For many local businesses, these changes are big. People working in real estate, law, and accounting will be reporting entities now. This is new for them, and it brings a lot that they have to do. You will have legal duties to know, lower, and handle your business's risks with money laundering and terrorism financing.


Your compliance teams will have to set up and keep an AML/CTF program running. They will check each customer carefully. They will also need to report some transactions and any suspicious acts to AUSTRAC. This is a big shift that will need new ways to work, new tools, and new training for your staff.


If you do not follow the rules, you can face big fines and damage to your business's name. So, it is very important to get ready for these reporting entity requirements. This can help keep your business safe and help make the financial world safer for all of us.


Entities and Sectors Impacted by AML Tranche 2

The coming changes are set to cover a lot more ground, bringing new areas into the rules as reporting entities. In the past, the AML/CTF rules were mostly for banks and the gambling businesses. Now, with Tranche 2, these rules will also apply to a group called Designated Non-Financial Businesses and Professions (DNFBPs).


This group has many different professional service providers. They offer a designated service, like helping with big payments or looking after client money. If you run a business in these areas, you need to know your new place under these rules. The next parts will talk more about which sectors are affected by this.


Professional Services: Lawyers, Accountants, and Real Estate Agents

The main point of AML Tranche 2 is to look at professional services. These businesses can be used by people who do wrong things with money. People in these jobs often help their clients with money, help them buy and sell property, or set up trusts and companies. Because of this, criminals sometimes use these jobs to move illegal money.


The changes will now impact more professionals, who will need to start following new rules. This will include:

  • Lawyers and conveyancers

  • Accountants and tax agents

  • Real estate professionals, including buyer’s agents and property developers


These businesses will have to watch and check every client transaction with care. There will still be rules about legal professional privilege, and these will be part of the plan before everything starts. All groups will still have to let authorities know about any suspicious activities they see.


Coverage of Dealers in Precious Metals and Stones

The Tranche 2 reforms also cover dealers in precious metals and precious stones, along with professional services. These items are often used for money laundering. They are valuable, can be moved around easily, and people can trade them quietly with little attention.


The Australian government wants more openness in the trade of expensive goods by including these dealers in the AML/CTF regime. With this new rule, it will be harder for criminals to use cash from crime to buy gold, diamonds, or other precious stones and hide the real source of their money.


Dealers will have to use due diligence with their customers. They must watch over their deals and let AUSTRAC know about any suspicious activities. This step puts Australia in line with how other countries keep their precious metals and stones sector safe from financial crime.


Key Changes Introduced by AML Tranche 2

The amendment bill for Tranche 2 brings in big changes to the way new businesses have to work. The reformed laws make the CTF Act cover more areas. Now, there is a fresh set of rules made to spot and stop financial crime better.

If your business is new to these rules, things may seem very different and big. You must go from doing risk checks casually to following a set system that is written down. It needs you to be active in keeping up with these rules. You will want to learn what the CTF Act asks you to do, know the details, and plan to fit all of it into what you do each day. The amendment bill and these reformed laws mean your company has more to do to stay away from trouble with financial crime.


New Obligations Under Revised Legislation

Under the new laws, businesses designated as reporting entities will have several core obligations. These are not optional; they are legally mandated requirements designed to ensure every entity plays its part in protecting Australia's financial system. Are you prepared to meet them?


The primary duties are centred on knowing your customer, monitoring their behaviour, and reporting potential risks to the authorities. These obligations apply whenever you provide a designated service, such as when onboarding a new client or processing a significant transaction.


The key requirements can be summarised as follows:

Your Obligation

What it Means

Enrol with AUSTRAC

You must register your business with the regulator and keep your details current.

Have an AML/CTF Program

You need a written plan detailing how your business will meet its AML/CTF obligations.

Conduct Customer Due Diligence (CDD)

You must verify your clients’ identities before providing services to them.

Ongoing Monitoring

You are required to monitor client transactions for unusual or suspicious behaviour.

Suspicious Matter Reporting

You must report any activities that seem suspicious to AUSTRAC promptly.

Record Keeping

You need to securely store identity information and transaction records for a specified period.

Expanded Risk and Compliance Demands

The start of Tranche 2 focuses more on strong risk management than before. It is not enough just to act when problems come up. Now, businesses need to do formal risk assessments. This will help them find where they could be at risk for money laundering or terrorism financing.


Your compliance teams have to take care of this work. They need to plan and use ways that lower these risks. This means setting up controls inside your business. It also means building policies and steps that match your business's size, type, and how it works.


This is not a one-time job. As criminal ways change, your risk management also has to change. There must be regular checks on your AML/CTF program. Simply having rules is not enough. You need a feeling of following these rules from the top leaders to everyone in the organisation.


Compliance Steps for Businesses under AML Tranche 2

Taking steps early to follow the new rules will help your business adjust more easily when they start. It is important to know what you have to do and to create a clear plan on how to get there. This is more than just checking off some tasks. You need to build a strong system to follow the rules.


Some key things to focus on are setting up ways to keep up with ongoing customer due diligence during every business relationship. It is also helpful to appoint a CTF compliance officer, who will look after the full CTF compliance setup at your company. These are some of the first things to do that will help your business get ready for these new requirements. The next sections explain these steps in more detail.


Adopting Effective AML/CTF Programs

An effective AML/CTF program is at the heart of your work to stay compliant. This program is not just a piece of paper on a shelf. It is a helpful guide that shapes how your business fights financial crime. You need to have this written down and get it approved by your senior management.


Your CTF program should explain how you will use different CTF measures. These steps help you find, lower, and handle risks. The program should cover things like customer identity checks, watching transactions, keeping records, and reporting. Make sure it fits your business needs and think about your clients, the services you offer, and the places you work in.


Since most new jobs will have to start using these rules by mid-2026, it is a good time to get ready and build your program now. You should look at how your business runs and spot anything that might cause problems. Give people clear roles, and you will have a working system that is ready when you need it.


Enhancing Customer Due Diligence Procedures

Customer due diligence is a key part of your new duty. It means you need to check that your clients are the people they say they are before you work with them. This stops bad people from using fake names to get into the financial system.


Your duty does not stop after you check someone’s identity at first. You have to keep doing ongoing customer due diligence. This means you watch how your clients use your services and see what they do. That way, you can spot when something does not match what you know about them and if there may be a suspicious matter.


Good due diligence steps should have the following:

  • Collect and check client ID details using trusted sources.

  • Find out who really owns any companies or trusts that you deal with.

  • To know the reason and goal for the business relationship with your client.

  • Do better checks when you have customers who may be at higher risk.


Conclusion

To sum up, knowing about AML Tranche 2 is important for any business that has to deal with money laundering rules in Australia. There are big changes to look at, and these changes affect many areas, like professional services and people who deal in precious metals. If you follow the new rules and work on your customer due diligence and other due diligence steps, then you will meet the legal needs and help keep your business safe from risks. It is good to stay updated and act in the right way to keep up with these changes. If you want help that fits your business for AML Tranche 2 problems, get in touch with us for a free chat with our experts.


Frequently Asked Questions


How do I determine if my business is covered by AML Tranche 2?

Your business is probably included if you work as a lawyer, accountant, conveyancer, or in real estate. This is true if you give a designated service the way it is explained under the CTF Act. The safest way to check is to look at the official guidance on the AUSTRAC website. There, you can see if you are one of the new reporting entities.


What are the first steps to get compliant with AML Tranche 2?

Start by knowing what your own CTF obligations are. You need to carry out a proper risk management check. Pick someone or a team to handle these things for you. Begin work on your CTF program, and set up a plan for teaching your people and putting customer due diligence steps in place. Keep up with ongoing customer due diligence as the next step.


Where can I access official information and support for AML Tranche 2 compliance?

The official place to get all the relevant information is the AUSTRAC website. You can find guidance, educational materials, and updates about the public consultation there. Your industry associations might also give you some useful support and resources to help you get ready.

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