Your Complete Guide to Tranche 2 AML/CTF Compliance

Tranche 2 of Australia's Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) reforms brings new obligations to professional services that were previously exempt. If you're an accountant, lawyer, real estate agent, or trust and company service provider, here's what you need to know.

What is Tranche 2?

When Australia enacted the AML/CTF Act in 2006, certain professional sectors were excluded from reporting obligations. Tranche 2 extends these obligations to "gatekeeper" professions — those who provide services that can be exploited for money laundering or terrorism financing. This includes accountants, lawyers, conveyancers, real estate agents, trust and company service providers, and dealers in precious metals and stones. See our industry solutions to understand how compliance obligations differ across each sector.

Key deadlines

• March 31, 2026 — Enrolment deadline. All newly covered entities must enrol with AUSTRAC as reporting entities.
• July 1, 2026 — Obligations begin. Full AML/CTF compliance obligations take effect, including customer due diligence, ongoing monitoring, and reporting.

What you need to do

To be compliant under Tranche 2, your business must:

1. 1Develop an AML/CTF program — A documented program that identifies, mitigates, and manages money laundering and terrorism financing risks specific to your business. Our AML/CTF compliance guide covers exactly what your program must include.
2. 2Perform customer due diligence (KYC) — Verify the identity of your clients before providing designated services. This includes collecting identification documents and, in some cases, biometric verification. Read our Tranche 2 reform guide for the full scope of CDD obligations that apply to your business.
3. 3Screen against sanctions and PEP lists — Check clients against government sanctions lists and politically exposed persons (PEP) databases.
4. 4Monitor ongoing transactions — Track client activity for suspicious patterns and maintain records of all transactions.
5. 5Report to AUSTRAC — Submit suspicious matter reports (SMRs), threshold transaction reports (TTRs), and international funds transfer instructions (IFTIs) as required.
6. 6Train your staff — Ensure all relevant employees understand their AML/CTF obligations and can identify red flags.

How IntelliCompli helps

IntelliCompli is purpose-built for Tranche 2 compliance. The platform covers every obligation in a single dashboard:

• AML/CTF program builder — Generate a compliant program tailored to your business in minutes.
• KYC identity verification — Verify clients with document and biometric checks at $3 per verification.
• Sanctions and PEP screening — Automated screening against global watchlists.
• Transaction monitoring — Intelligent rule-based monitoring with risk-scored alerts.
• AUSTRAC reporting — Generate and submit regulatory reports directly from the platform.
• Staff training — Built-in training modules to keep your team up to date.

Don't wait until July

The March 31 enrolment deadline is approaching. Setting up your compliance program now gives you time to onboard your team, verify clients, and be ready when obligations begin on July 1. View our pricing plans — all plans are free until July 2026.