Understanding Tranche 2: What Australian Accountants Need to Know

Tranche 2 of Australia's AML/CTF reforms extends obligations to accountants, lawyers, and real estate agents. Here's what your firm needs to understand about the upcoming changes.

What is Tranche 2?

Tranche 2 refers to the second phase of Australia's Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) reforms. While Tranche 1 covered financial institutions, Tranche 2 extends these obligations to designated non-financial businesses and professions (DNFBPs), including accountants.

Key Dates

The legislation is expected to take effect on 1 July 2026. This gives accounting firms approximately 18 months to prepare their compliance programs.

What Services Are Covered?

The following accounting services will likely be covered under Tranche 2: - Company formation and management - Trust creation and administration - Real estate transactions - Managing client money and securities - Tax planning involving certain structures

What You Need to Do

1. Assess your exposure - Determine which of your services fall under the new obligations 2. Develop an AML/CTF program - Create policies and procedures tailored to your firm 3. Train your staff - Ensure all relevant personnel understand their obligations 4. Implement systems - Put in place processes for customer due diligence and suspicious matter reporting

Getting Started

The best time to start preparing is now. Firms that begin early will have more time to develop robust, practical programs that integrate smoothly with existing workflows.