With the 1 July 2026 deadline fast approaching, Tranche 2 businesses need to act now. Whether you're an accountant, lawyer, real estate agent, or jeweller, this checklist covers every critical step.
1. Understand Your Obligations
Under the reformed Anti-Money Laundering and Counter-Terrorism Financing Act 2006, Tranche 2 entities must:
- Register with AUSTRAC (enrolment opens 31 March 2026, deadline 29 July 2026)
- Develop and maintain an AML/CTF program
- Conduct customer due diligence (CDD) on all clients
- Monitor transactions for suspicious activity
- Report Suspicious Matter Reports (SMRs) and Threshold Transaction Reports (TTRs)
- Keep records for 7 years
2. Register with AUSTRAC
AUSTRAC enrolment opens on 31 March 2026. You'll need:
- Your ABN and business details
- Nominated compliance officer information
- Details of your designated services
Don't wait until the last minute — registration can take time to process.
3. Appoint a Compliance Officer
Every reporting entity needs a compliance officer at management level. This person is responsible for:
- Overseeing the AML/CTF program
- Ensuring staff training is up to date
- Reporting obligations are met
- Liaising with AUSTRAC
4. Develop Your AML/CTF Program
Your program must include Part A through Part F:
| Part | Coverage |
|---|---|
| Part A | Governance & risk assessment |
| Part B | Personnel & training |
| Part C | Customer due diligence |
| Part D | Transaction monitoring |
| Part E | Reporting obligations |
| Part F | Record keeping & review |
AUSTRAC has published industry-specific starter kits — AML Mate uses these as templates to generate your program automatically.
5. Set Up Customer Due Diligence
CDD is the backbone of AML compliance. At minimum, you need to:
- Verify identity of all customers before providing designated services
- Assess ML/TF risk for each customer relationship
- Conduct enhanced due diligence (EDD) for high-risk customers
- Screen against sanctions lists (DFAT consolidated list)
- Check for Politically Exposed Persons (PEPs)
Transitional rule: For existing customers as of 1 July 2026, you have a grace period to complete initial CDD. But new customers from day one require full verification.
6. Implement Transaction Monitoring
You need systems to detect:
- Transactions over $10,000 AUD (TTR threshold)
- Structuring or splitting of transactions to avoid thresholds
- Unusual patterns inconsistent with the customer's profile
- Transactions involving high-risk jurisdictions (FATF grey/black list countries)
7. Train Your Staff
All employees who handle designated services must complete AML/CTF training covering:
- What ML/TF is and why it matters
- Your business's specific AML/CTF program
- How to identify suspicious activity
- Reporting procedures (internal and external)
- Record keeping requirements
Training must be completed within 30 days of starting employment and refreshed annually.
8. Prepare for Reporting
Familiarise yourself with AUSTRAC's reporting requirements:
- SMR: Must be filed within 24 hours of forming a suspicion (3 days in some cases)
- TTR: Must be filed within 10 business days for cash transactions over $10,000
- Annual compliance report: Due each year
Timeline Summary
| Date | Milestone |
|---|---|
| 31 March 2026 | AUSTRAC enrolment opens |
| 1 July 2026 | Full obligations commence |
| 29 July 2026 | Registration deadline |
Don't Wait
AUSTRAC has stated: "We don't expect perfection immediately, but we expect to see genuine effort to comply."
Start now. The businesses that prepare early will have the smoothest transition.
AML Mate can generate your complete AML/CTF program in 15 minutes. Start with a free compliance check to see where you stand.