From 1 July 2026, accountants, lawyers, real estate agents and other professional service providers will be subject to new anti-money laundering obligations under Australia's AML/CTF Tranche 2 reforms. As most organizations engage these professional service providers, changes in service delivery are expected to impact broader business operations. This article explains what's happening, where your team is most likely to feel the impact, and what you can do to be prepared.

Overview of AML/CTF Tranche 2: Scope and Directly Regulated Entities

Australia's anti-money laundering and counter-terrorism financing (AML/CTF) laws are expanding. Effective 1 July 2026, a new category of businesses—designated as Tranche 2 entities—will fall under AUSTRAC regulation, aligning with banks and financial institutions regulated since 2006.

The professions and businesses directly regulated under Tranche 2 include:

• Accountants, tax advisers and auditors

• Lawyers and conveyancers

• Real estate agents, buyer's agents and property developers

• Trust and company service providers

• Dealers in precious metals, stones and related products

It's worth noting that the regime does not regulate entire professions — it applies specifically to businesses that provide certain designated services. Organizations uncertain of their regulatory status should utilize AUSTRAC's eligibility checker as an initial assessment tool.

Not on this list? If your business engages any of these professionals — for accounting, legal, property or financial matters — there's a good chance the way those services are delivered to you will change. The next section explains where your team is likely to notice a difference.

Operational Impact: How Tranche 2 Modifies Professional Service Engagements

Here's where the impact is most likely to show up in practice.

1. When engaging your accountant, tax adviser or auditor

Before providing certain services, your accounting firm may be required to verify your identity and understand your business structure in more detail than before. This could apply even if you're an existing client — particularly when a new service is being provided or a new entity is involved.

2. When working with a lawyer on commercial matters

For transactions involving contracts, restructures, financing or M&A activity, your legal team may ask more detailed questions about the purpose of the transaction and the source of funds involved. This is a compliance requirement — not a reflection of any concern about your business.

3. When buying or selling commercial property

Real estate agents and property developers will likely be required to conduct identity and ownership checks as part of the transaction process. For corporate buyers or sellers, this may include questions about the ultimate beneficial owners of the entity involved. Note that standard leasing arrangements are generally not captured under Tranche 2 — though if your business is involved in a long-term lease of over 30 years, it may be worth checking with your adviser.

Four ways to get your team ready

While non-regulated businesses are exempt from AUSTRAC enrollment and formal compliance programs, proactive preparation is essential to streamline upcoming verification requests. If your accountants, lawyers or other advisers fall under Tranche 2, their new verification requests are simply part of their legal obligations. Here's what your team can do to be ready.

1. Consolidating Entity and Corporate Structure Documentation

Make sure your business's legal structure, ownership details, and any trust or group arrangements are documented clearly and up to date. If you're asked to explain who ultimately owns or controls your entity, you'll want to be able to answer quickly and accurately.

2. Preparing Identification for Key Personnel

Directors, senior managers, and anyone with authority over accounts or transactions may be asked to provide identity verification. Having current passports or driver's licences readily accessible — and knowing who in your organisation is likely to be asked — will save time when requests come in.

3. Factoring Compliance Timelines into Service Engagements

New or expanded engagements — particularly those involving contracts, property transactions, or corporate restructures — may take longer to get started while verification steps are completed. If you're working to a deadline, factor this in when planning timelines.

4. Clarifying Complex Group Structures

Businesses with multiple entities, holding structures, or trusts may face more detailed questions from regulated professionals. Having a clear, simple summary of your group structure — and who ultimately controls it — will help these conversations go smoothly.

The Tranche 2 reforms are ultimately about creating greater transparency in professional services — and for most businesses, the day-to-day impact will be manageable. Being prepared means fewer surprises and smoother dealings with your advisers when the changes take effect.

If you're unsure whether your own business falls under Tranche 2, or want to understand the obligations in more detail, AUSTRAC's resources are the best place to start — and a compliance specialist can help with anything specific to your situation.

Official sources:

• AUSTRAC — AML/CTF

• The Department of Home Affairs — Overview of the AML/CTF Amendment Act

Last updated: June 2026