AML Mate / Journal
Practical articles and guides for Australian professionals working through AML/CTF obligations.
104 articles Page 6 of 9
Under Tranche 2, the trip wire is not whether you do customer due diligence, it is when. From 1 July 2026 you have to identify and verify a new client before you provide the service, not after the deal is moving. Here is the timing rule in plain terms, the narrow exceptions, what initial CDD actually includes, and how to build a 'no service before checks' gate into your workflow with 9 days to go.
Most Tranche 2 coverage is written as if every firm has a compliance team. Plenty don't: solo conveyancers, sole-trader accountants, single-agent real estate offices. The reformed regime is risk-based and proportionate, so a one-person low-risk practice runs a genuinely lighter program than a 50-person firm. But lighter is not nothing, and a handful of duties have no size discount at all. Here is the whole job for a sole trader, scaled to one person, with 11 days to 1 July.
With under two weeks to go, plenty of small firms know they won't have everything polished by 1 July 2026. AUSTRAC has said it plainly: it doesn't expect perfection on day one, but it does expect genuine effort to comply. That's reassuring, and it's widely misread. Genuine effort is not the same as 'we'll get to it.' Here is what the phrase actually means, the handful of obligations that get no grace at all, and the realistic minimum a small firm should have running on 1 July.
Generating an AML/CTF program is the easy part. From 1 July 2026 AUSTRAC expects you to operate it — apply customer due diligence to every new client, screen and monitor, keep records, and report when you have to. A program that sits in a drawer is not compliance. Here is the day-one operating rhythm for a small firm: what you do on every engagement, what runs in the background, and what only happens when something is off.
With fifteen days until 1 July 2026, the fear among newly regulated firms is that they need a finished, perfect AML/CTF program by the deadline. The Act asks for something narrower and far more achievable: a single risk-based program, built on a current ML, TF and PF risk assessment, that you are genuinely following — not a flawless document. Here is what 'in place' actually requires on 1 July, what can legitimately wait, and how to get there in the time that is left.
On 18 June 2026, for the first time, all four Tranche 2-affected professions — lawyers, accountants, conveyancers and real estate agents — meet AUSTRAC CEO Brendan Thomas in the same room. The headline is the format. The reason that format had to exist is reliance: when a single property transaction passes through four newly regulated firms, whose customer due diligence is it? With 13 days to 1 July, this is the question every firm should be answering before the regulator asks.
The global compliance industry has arrived for Australia's 90,000 newly regulated firms: certifications, conferences, training partnerships. None of it is a legal requirement. The AML/CTF Act does not require your compliance officer to hold any certification, and the training obligation is risk-based and tailored to your own program. Here is what the law actually asks of a small firm, when a certification is genuinely worth it, and where your money is better spent three weeks out from 1 July.
Two dates are doing the rounds for the 90,000 newly regulated firms: 1 July 2026 and 29 July 2026. They are not the same deadline, and treating them as one is how firms get caught out. 1 July is the day your AML/CTF obligations switch on and your program has to already exist. 29 July is the administrative deadline to enrol with AUSTRAC. Here is exactly what each date requires, why the order matters, and what AUSTRAC actually expects with three weeks to go.
Most of the Tranche 2 noise is aimed at the 90,000 firms joining the regime on 1 July. But existing reporting entities have their own cliff on the same date. If you were enrolled before 31 March 2026, the rules let you keep running a reduced AML/CTF program and governance setup until 30 June. From 1 July that relief is gone, and the full reformed program, with its single risk-based structure and independent evaluation, applies in full. Here is what ends, what begins, and what to do in the three weeks that are left.
On 26 May 2026 the Federal Court ordered two financial services businesses to pay $50,000 and $45,000, plus costs, after they ignored AUSTRAC infringement notices of $18,780 each. The original failure was mundane: they did not lodge their annual compliance report. For the 90,000 Tranche 2 firms entering the regime on 1 July, this is the most instructive small case of the year. The annual compliance report is the single most predictable obligation you will have, and this is what happens when a routine failure meets a decision to ignore the regulator.
On 8 May 2026 AUSTRAC launched two targeted supervisory campaigns into the virtual assets sector: a 'ramps and rails' campaign across 36 over-the-counter crypto-to-cash operators, and a readiness-and-governance review of 27 local exchanges. The crypto sector entered the reformed AML/CTF regime on 31 March. Tranche 2 enters on 1 July. So this is not a crypto story. It is a live demonstration of exactly how AUSTRAC supervises a newly regulated sector the moment its obligations switch on, and a preview of what the 90,000 lawyers, accountants, real estate agents and dealers should expect from July.
On 29 May 2026 the Australian Government committed more than $5 million to AUSTRAC's Pacific financial intelligence work, including AI to detect illicit money flows. Read past the Pacific framing and it is a clear statement of how AUSTRAC now operates: intelligence-led, AI-assisted, cross-border, and built on the reports it receives. From 1 July 2026, around 90,000 Tranche 2 firms become the sensors that feed it.
