What Tranche 2 AML Means for Your Accounting Firm

Australia’s anti-money laundering rules are expanding, and many accounting firms will be brought into the
regime for the first time from 1 July 2026.
In plain terms, if your firm provides certain higher-risk services, you will need a more formal way to check
clients and keep records.

What is “Tranche 2”?

For years, AML/CTF rules have mainly applied to banks, casinos, and other traditional financial institutions.
Tranche 2 extends similar obligations to more professional services businesses, including accounting firms that
provide specified designated services.
The key point is that Tranche 2 is service-based, not profession-based. Being an accountant does not
automatically make you a reporting entity. Providing particular types of services does.

Which services put you in scope?

• Manage client money, securities, or other assets
• Manage bank or investment accounts
• Set up or manage companies, trusts, or other structures
• Provide a registered office or business address for entities
• Buy or sell business entities

Many firms already do some of this as part of standard advisory work, for example, forming companies,
establishing SMSFs, or handling trust administration. Under Tranche 2, those engagements may now attract
AML/CTF obligations.

What obligations will you have?

• Enrol with AUSTRAC within the required timeframe
• Appoint an AML/CTF Compliance Officer, usually a senior person
• Put an AML/CTF program in place that explains how you identify and manage risk
• Carry out customer due diligence before providing designated services
• Keep clear records so you can show what checks were done and when
• Be ready to file Suspicious Matter Reports if something does not look right

None of these are new ideas for financial institutions, but they will be new for many accounting practices.

Why start thinking about this now?

• Time pressure — obligations start from 1 July 2026 for in-scope services. If you only start planning in June, you are likely to rush.
• Operational impact — these rules change how you onboard clients, not just what you write in a policy.

Early preparation gives you time to decide which services you will keep offering, how you will structure your
workflow, and how you will train your team.

A sensible first step

A simple starting point is to map your services against the likely designated services list and mark which
engagements are clearly in, clearly out, or uncertain.

• Confirm your interpretation with AUSTRAC guidance or advisers
• Decide whether to continue, modify, or stop any higher-risk services
• Begin drafting a practical AML/CTF program that reflects what your firm actually does

Tranche 2 is a significant change, but it does not have to be overwhelming. Treated as a structured project
over the coming months, it is manageable for most firms.