On 18 June 2026, the four professions about to enter the AML/CTF regime will sit in the same virtual room as AUSTRAC CEO Brendan Thomas. Lawyers, accountants, conveyancers, and real estate agents, opened by the regulator, hosted by InfoTrack across a 90-minute panel, three days after this article publishes and 13 days before 1 July. It is the first cross-sector Tranche 2 forum of its kind, and that fact alone is the headline. (InfoTrack to host first cross-sector AML/CTF forum)
Every prior AML/CTF forum has been single-sector. Lawyers talking to lawyers. Accountants to accountants. Conveyancers to conveyancers. That format made sense while each profession was getting its head around obligations that, individually, look quite different on paper. The reason a cross-sector forum has to exist now, with 13 days left, is that the obligation that matters most to a Tranche 2 firm is not the one that lives inside its own profession. It is the one that lives in the seam between professions.
What Is Actually Happening on 18 June
The session is 90 minutes, virtual, complimentary. Brendan Thomas opens. The confirmed panel includes Bobbie Wan, Head of Regulatory Policy and Strategy at the Law Society of New South Wales, and Jennie Tonner, President of the Australian Institute of Conveyancers NSW, alongside representatives from the real estate and accounting sectors. InfoTrack CEO John Ahern framed the rationale plainly: for the first time, all four affected professions are in the same room with the regulator, addressing questions "not resolvable in a single-sector setting."
Read that phrase carefully. "Not resolvable in a single-sector setting" is regulator-adjacent language for: we have spent months trying to answer these in separate rooms and we cannot, because the answers are about what the rooms have in common. The agenda confirms it. Three topics, in order: customer due diligence obligations and the solicitor-client relationship; reliance provisions when multiple regulated parties share a transaction; and what a compliant program looks like for firms of varying sizes and practice areas. The middle one is the centre of gravity for everyone else.
The Question That Needed All Four Sectors in One Room
Consider a single, ordinary property transaction in suburban Sydney. A young couple buys their first home. The deal touches, in sequence: a real estate agent who brokers the sale, a conveyancer who handles the paperwork, a solicitor who advises the vendor's family trust, and an accountant who sets up the SMSF structure on the buyer's side. From 1 July 2026, all four of those firms are reporting entities under the reformed AML/CTF Act. All four are providing a designated service tied to that single transaction. (What counts as a designated service under Tranche 2)
Now ask the question. Whose customer due diligence is the customer due diligence of record?
In the comfortable, single-sector version, each profession answers separately and confidently. The real estate agent reads the real estate guidance and concludes: my obligation is to identify the buyer and the seller. The conveyancer reads the conveyancing guidance and concludes the same. The solicitor reads the legal-sector guidance, and the accountant reads the accountant starter kit, and each concludes the same. Four firms, four CDD obligations, four sets of identification documents, on one transaction. Multiplied across 90,000 newly regulated firms and millions of transactions, that is an absurd amount of duplicated friction, and it is exactly what reliance provisions exist to manage. (What an AML/CTF program covers, Part A to F)
The reliance provisions in the reformed Act let a reporting entity rely, in defined circumstances, on customer due diligence already performed by another reporting entity in the chain. The wording matters. So do the conditions. So does what happens, in practice, when reliance is asserted and the customer turns out to be someone the chain should have caught. The point of the cross-sector forum is that no profession can answer those questions for itself, because reliance is, by definition, a question about the firm next door. (Customer due diligence checklist for Australia)
Why AUSTRAC Is Opening It Personally
It would have been easy to send a director of supervision, or a sector lead, to open this forum. AUSTRAC sent the CEO. That choice carries information.
The clearest reading is that AUSTRAC treats the four Tranche 2 sectors not as four separate regulatory populations but as one. The regulator is signalling, at the top of its org chart and 13 days before commencement, that the answer it expects from each firm is an answer that accounts for the others. The supervision campaigns we have already seen in adjacent sectors point the same way: AUSTRAC supervises cohorts, builds its own lists, and assesses readiness proactively rather than reactively. (How AUSTRAC ran its crypto supervision playbook) Treating the four Tranche 2 professions as a single cohort with shared seams is the next logical step in that pattern.
For an individual firm, the implication is uncomfortably clean. Your defence on 2 July cannot be "I read my own sector's starter kit." The regulator has visibly designed its readiness check around the spaces between sectors. The cheapest moment to be on the right side of that check is now, before the seams have been tested by real transactions and real SMRs.
Three Things to Bring to (or Take Away From) the Forum
Whether you attend Thursday or not, the forum's agenda is the readiness agenda. Three concrete checks should be done by the end of next week.
Map your role in the transactions you actually touch. Pick the five most common matter types your firm sees. For each, write out who else is around the table by 1 July: the agent, the conveyancer, the lender, the accountant, the trust company, the bullion dealer. The chain matters because the reliance question is downstream of it. A firm that cannot list the chain cannot decide whether to be the relier or the relied-upon, let alone evidence either. (What designated services trigger Tranche 2 for legal services)
Decide your default position on reliance, sector by sector. Some firms should default to performing their own CDD on every customer, because the friction is low and the audit trail simple. Other firms, particularly those at the end of a chain, will want to rely on prior CDD where the conditions permit. The wrong position is the unspoken one, which is what reliance frequently becomes when nobody has actually decided. Your AML/CTF program is the place to record what you have decided and why. (What real estate firms should set up before 1 July)
Identify the seam-of-record for each chain you participate in. For a property transaction that runs agent → conveyancer → solicitor → accountant, who is the firm whose CDD other firms can soundly rely on, and what evidence travels with the customer? The forum's third topic, what a compliant program looks like for firms of varying sizes, becomes practical here. A small firm at the end of a chain has very different program ergonomics from a large firm at the start of one. Both need to know which they are.
The One Sentence To Take Away
For the next 13 days, the question your firm should be answering is not "what are my AML/CTF obligations." That question has answers, and the starter kits cover them. The question is "where do my obligations end and the next firm's begin." That answer does not exist inside any one starter kit, which is why AUSTRAC and the four sectors are spending 90 minutes on 18 June trying to articulate it in the same room. The firms that walk into 1 July with that boundary already mapped are the ones that will not find out where it actually sat from a readiness officer eight weeks later.
Where AML Mate Fits
AML Mate builds the Tranche 2 program around the question the forum is wrestling with. Part A to F, mapped to the designated services your firm actually provides, with a customer due diligence module that records your default position on reliance, the conditions under which you rely or are relied upon, and the evidence trail that goes with it. The free compliance check at /check gives you a five-minute read on whether your program answers the seam-of-the-chain question, with 13 days to fix it if it does not. Thursday's forum exists because nobody else has resolved the question yet. The firms that resolve it for themselves before 1 July are the ones who will not need it resolved for them after.