From 1 July 2026, Australia’s anti-money laundering and counter terrorism financing (AML/CTF) laws will change.[1] For many accountants and lawyers, the impact will be significant.
Under the AML/CTF reforms, a range of professional services that were previously outside the regime will become regulated by AUSTRAC[2]. If your firm helps clients set up companies or trusts, manages client money, or assists with certain transactions, you may soon have formal AML/CTF obligations for the first time.
This article explains what's changing, who is in scope, and why now is the right time to start preparing.
Cleardocs Team
What is “Tranche 2” — in plain English
Australia’s AML/CTF regime has traditionally focused on banks, financial institutions and gambling providers. The “Tranche 2” reforms expand the regime to cover a broader group of “gatekeeper” professions — including accountants, lawyers, conveyancers, real estate professionals and trust and company service providers.
The policy goal is simple: these professions often sit at the entry point to complex financial structures and transactions, and regulators consider them well‑placed to identify and reduce ‘ML/TF risk’[3] early.
Who is likely to be affected
You may be regulated if your firm provides designated services and has a geographical link to Australia.
For accountants and lawyers, designated services can include (at a high level):
- Assisting to establish, buy, sell or restructure companies or trusts
- Acting in transactions involving client money or assets
- Helping clients plan or execute certain transactions
- Providing trust and company services, such as acting or arranging for someone else to act in nominee or trustee roles
Whether you are “captured” depends on the services you actually perform, not your job title. AUSTRAC has published an official checker to help firms assess this.
What does "designated services" really mean?
A designated service is a specific activity listed in the AML/CTF Act that triggers regulation. Importantly, in respect of certain services assisting or acting on behalf of a client can be enough to be considered to be providing a designated service— even where the professional is not directly handling funds.
For example, helping a client set up a company or trust structure, or facilitating control changes, may fall within scope of providing a designated service depending on how the service is delivered.
Key dates to know
- 31 March 2026 – AUSTRAC enrolment opens for newly regulated Tranche 2 entities
- 1 July 2026 – Most AML/CTF obligations commence for Tranche 2 entities
- 29 July 2026 – Deadline to be enrolled if you provide a designated service
Why early awareness matters
While July 2026 may feel distant, AML/CTF compliance is not something firms can switch on overnight. New obligations include risk assessments, client due diligence, record‑keeping and staff training — all tailored to your actual workflows.
Firms that start early can spread the workload, avoid last‑minute pressure, and build processes that fit how they already work.
Where to start: AUSTRAC checker
AUSTRAC recommends using its “Check if you may be regulated” tool as a starting point.
If you haven’t already, use AUSTRAC’s checker to confirm if your services are likely regulated. Then, start mapping where your firm captures client and matter information.
Why ‘gatekeeper’ professions are now in scope — and what it means for trust & company work
For many accountants and lawyers, the regulation of Tranche 2 entities feels like a philosophical shift: from trusted adviser to regulated “gatekeeper”.
AUSTRAC’s view is that services like company formation, trust structuring and SMSF establishment are not neutral paperwork — they can be misused to obscure ownership, move value, or create layers that prevent detection.
That’s why the reforms focus less on prescriptive rules and more on outcomes‑based compliance:
- Do you understand who your client really is?
- Do you know who ultimately owns or controls the structure?
- Can you explain why a transaction makes sense in context?
This aligns with workflows many firms already perform — particularly around trust deeds, company registration and structural changes to legal entities — but it raises expectations about consistency, evidence and auditability.
Firms that embed AML/CTF thinking into existing trust and company workflows — rather than bolting it on later — are likely to experience less friction, fewer re‑work loops, and stronger client confidence over time.
[1] The reforms will be introduced through amendments to the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act).
[2] Australian Transaction Reports and Analysis Centre.
[3] ML/TF risk is defined in the AML/CTF Act as the risks of money laundering, financing of terrorism and proliferation financing that a reporting entity may reasonably face in providing designated services to a customer.
This article is general information only and does not constitute legal advice. Readers should seek independent legal advice before acting on the information provided.
