Tranche 2: what the AML/CTF reforms mean for your practice
Kestrel Assurance · 1 August 2026
Australia has undertaken the largest expansion of its AML/CTF regime in two decades. The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 extended obligations from around 17,000 businesses to more than 100,000.
Who is now captured
The regime regulates designated services, not professions. You are a reporting entity if you provide one or more designated services with a link to Australia, in the course of carrying on a business. Newly captured groups include:
- Accountants and tax practices — forming companies and trusts, managing client money, property and business transactions.
- Law firms — trust account and conveyancing work, financing transactions, nominee and registered-office arrangements.
- Real estate professionals — brokering, planning or executing the sale, purchase or transfer of real estate (with a dual-customer CDD rule covering both buyer and seller).
What you must put in place
Every reporting entity must enrol with AUSTRAC, appoint a compliance officer, complete a business-wide risk assessment, maintain a written AML/CTF program, perform customer due diligence, report suspicious matters, and keep records for seven years.
Missed the deadline?
Late enrolment with a documented remediation plan is the right path. Acting now — and evidencing the steps you've taken — is far better than remaining unregistered.
General information only, current as at publication. Not legal advice.