The broader educational guide to the Tranche 2 reforms
On 1 July 2026, the rules changed for a large group of Australian professionals — including, for the first time, accountants.
If you've noticed your accountant, lawyer or real estate agent suddenly asking more questions and requesting more identification, this is why.
The short answer
Australia's Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) regime has been expanded through what's known as the “Tranche 2” reforms. From 1 July 2026, professions that previously sat outside the regime — accountants, lawyers, conveyancers, real estate professionals, and dealers in precious metals and stones — are now regulated by AUSTRAC when they provide certain specific services, known as “designated services.” This affects around 80,000 additional Australian businesses.
Why this happened
Australia's AML/CTF regime previously covered banks, financial institutions and casinos, but left a gap around the professional services often used to move, hide or legitimise the proceeds of crime — setting up complex company and trust structures, managing large transactions, or facilitating property purchases. These professions are recognised internationally as “designated non-financial businesses and professions,” and closing this gap brings Australia in line with global standards set by the Financial Action Task Force.
Who is actually affected
| Profession | The kind of service that triggers obligations |
|---|---|
| Accountants | Managing client funds, assisting with certain transactions, forming or managing companies and trusts |
| Lawyers and conveyancers | Assisting with property or business transactions, acting as a director, trustee or nominee, managing client funds |
| Real estate professionals | Assisting with the sale or purchase of real property |
| Trust and company service providers | Forming, managing or acting on behalf of companies and trusts |
| Dealers in precious metals and stones | Certain transactions above defined thresholds |
Importantly, the regime doesn't regulate an entire profession — it regulates specific services. An accountant might provide some services that fall within scope and others that don't, depending on exactly what's being done for a client.
What it actually requires of a regulated business
Enrolment with AUSTRAC. Newly regulated businesses needed to enrol, with enrolment opening 31 March 2026 and required to be completed by 29 July 2026.
An AML/CTF program. A documented, risk-based framework tailored to the specific business, approved at a senior level.
A nominated AML/CTF compliance officer. A named person at management level responsible for the program.
Customer due diligence. Verifying client identity and, for businesses and trusts, understanding who ultimately owns or controls them — covered in more detail in its own guide.
Ongoing monitoring and suspicious matter reporting. Reporting to AUSTRAC if a transaction or client relationship raises genuine concern.
Record-keeping. Retaining relevant records for at least seven years.
Why this matters even if you're not one of the regulated professions
If your business is a client of an accountant, lawyer, conveyancer or real estate agent — which almost every business is — you're likely to notice the practical effects even though the compliance obligation sits with them, not you. Expect more identification requests, more questions about the purpose of a transaction, and potentially more documentation required before certain services can be provided. This is covered in detail in its own companion guide, written specifically for clients experiencing this from the other side.
The scale of the change
This is one of the largest expansions of Australia's AML/CTF regime since it began in 2006, bringing a substantial new group of professional service providers under active regulatory supervision for the first time. Penalties for non-compliance are significant — reaching into the tens of millions of dollars for corporate contraventions — which is why regulated businesses are treating implementation seriously rather than as a minor administrative update.
A quick self-check
Do I engage an accountant, lawyer, conveyancer or real estate agent for services that might now be “designated services” under the reforms?
Have I noticed new identification or documentation requests from any of these professionals recently?
Do I understand this is a change in their obligations, not a reflection of any concern about me specifically?
If I'm a business owner in one of the affected professions myself, have I confirmed my enrolment and compliance obligations?
Free official resource
AUSTRAC provides comprehensive guidance on the Tranche 2 reforms and how to determine if a business is affected.
austrac.gov.au — AML/CTF reform https://www.austrac.gov.au/business/how-comply-and-report-guidance-and-resources
When should you get professional help?
you're a business in one of the newly regulated professions and need to confirm your enrolment and compliance status;
you're unsure whether a specific service you provide counts as a “designated service” under the reforms;
you've been asked for identification or documentation by a professional adviser and want to understand why; or
you want to understand how these changes might affect an upcoming transaction, such as a property purchase or business sale.
Continue learning
→ Why Is My Accountant Asking for My ID and Information About My Business?
→ What Accounting Records Do I Need to Keep — and for How Long?
→ I'm Thinking About Buying a Business — What Financial Information Should I Check Before I Buy?
SKC Accounting | Knowledge Centre | Knowledge Guide 044
Last reviewed: August 2026
General information only. This guide does not take into account your individual circumstances and is not a substitute for professional accounting, taxation, legal or financial advice.