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Tranche 2 AML/CTF Regime Implementation 

If you are an Australian Tranche 2 business, you have an obligation to implement the updated AML/CTF regime by 1 July 2026 (31 March 2026 for VASPs*).

We can help!

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Know more - this page provides a range of resources in helping you understand and decode the AML/CTF requirements. We will keep adding more resources, as we go along. So do bookmark the page, and subscribe to our newsletter for updates (on the Home page).
 

* refer FAQs / details below on Transitional Rules

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FAQs & Blogs

  • AUSTRAC proposal on proposed Transitional Rules to defer certain new obligations - refer here.

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  • Understanding correctly the scope of Designated Services for your business - refer here.

 

  • 'Reporting Group' under the new AML/CTF regime - refer here.

 

  • Appointing an AML/CTF Compliance Officer for your business - refer here.

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  • Engaging an AML/CTF Adviser for advisery services - refer here.

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Key Dates

If you are Tranche 2 designated services provider, know key compliance dates - click here.

Resources - Read our AML/CTF reforms and Tranche 2 related Blogs

Read our ​blogs on AML/CTF reforms and Tranche 2 developments- click here.​​

Regulatory Resources

Key regulatory resources relevant for you - click here.​

Program Starter Kits (Do it yourself)

AUSTRAC has released AML/CTF Program Starter Kits for Tranche 2 entities. Read more about this. â€‹

Key Dates

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I.  Real Estate, Precious Stones /Metals, and Professional Services Provider Businesses

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If you are providing designated services in regards to any of the following businesses (existing as on 1 July 2026):​

  • Real Estate Business

  • Precious Metals, Stones and Products

  • Professional Services Provider (including lawyers, accountants, conveyancers, trust and company service providers).

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Your compliance deadline - 1 July 2026

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  • The new AML/CTF regime applies for your business from 1 July 2026

  • You must start complying with AML/CTF obligations from 1 July 2026. This means your AML/CTF compliance framework should be ready by this date

  • Your business must be enroled with AUSTRAC latest by 29 July 2026. The enrolment window will open from 31 March 2026, and you can apply earlier.

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What does readiness means?

  • Undertaken a Money Laundering / Terrorist Financing / Proliferation Financing Risk Assessment

  • Built an AML/CTF Compliance framework comprising program and related policies

  • Taken steps and readiness in place to operationalise the compliance program and framework.

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It also involves:

  • Designated an AML/CTF Compliance Officer

  • Undertaken relevant AML/CTF training for your staff.​​

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II. Virtual Asset Service Provider Businesses

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[Read the below together with our FAQs on Transitional Rules defering certain new obligation dates - click here]

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If you are a Virtual Asset Service Provider (existing as on 31 March 2026), including a Digital Currency Exchange services provider under the pre-Tranche 2 regime:

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​​Your compliance deadline - 31 March 2026

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  • The new AML/CTF regime applies for your business from 31 March 2026.

  • You must start complying with the updated AML/CTF obligations from 31 March 2026. This means your AML/CTF compliance framework should be ready by this date. 

  • You must apply for registering your business with AUSTRAC such that you are registered by 31 March 2026. You cannot provide designated services unless and until you are registered. (Note: AUSTRAC may notify transitional provisions in due course).

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Virtual Asset Services provided in the course of a business that are registrable include:

  • exchanging virtual asset for money; money for virtual asset; and virtual asset for another virtual asset

  • providing another designated service in connection with the offer or sale of a virtual asset

  • providing a virutal asset safekeeping service

  • Remitting or receiving remittance of funds, where this involves virtual asset.

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What does readiness means?

  • Undertaken a Money Laundering / Terrorist Financing / Proliferation Financing Risk Assessment

  • Developed and implemented an AML/CTF Compliance framework comprising program and related policies

  • Taken steps and readiness in place to operationalise the compliance program and framework.

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It also involves:

  • Designated an AML/CTF Compliance Officer

  • Undertaken relevant AML/CTF training for your staff.​​

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Program Starter Kits 

AUSTRAC has released AML/CTF Program Starter Kits for certain Tranche 2 entities (engaged in real estate, dealing in precious metals and stones, or carrying on the activities as lawyers, accountants and conveyancers).

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​​You can either customise yourself (DIY), or take help of an external AML/CTF expert like us to customise it to the size, nature and complexity of your business. 

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The starter kit, once customised to your business and approved by a senior manager, becomes your business’s AML/CTF program - click here to know more.

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Our Blogs on AML/CTF reforms and Tranche 2, and other related blogs

AML/CTF reforms and Tranche 2 related blogs:​​

  • AML/CTF Reforms - round up of updates since - Jul 2025 - Feb 2026 - click here

  • FAQs - referred above

  • Updated AML/CTF Act implementation - Some key pointers - click here

  • Tranche 2: Modernising and simplifying Australia's AML/CTF regime - click here

  • AML/CTF Amendment Bill - Towards a stronger AML/CTF regime - click here.

 

Other blogs by us, that are relevant read for Tranche 2 businesses:

  • ​AUSTRAC's Regulatory prioirites for 2025-26 - click here

  • AML & FCC developments in 2024 - click here

  • Suspicious activity indicators for designated service providers - click here

  • Australia's ML/TF National Risk Assessments - click here

  • Thematic Sanctions - click here

  • AUSTRAC Guidance on Data Breaches - click here

  • Failure to enrol your business as a reporting entity - click here.

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Regulatory Resources

Key regulatory resources relevant for your compliance efforts:

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  • AML/CTF Act (Future compilation, for the new regime) - click here

  • AML/CTF Rules (updated for the new regime) - click here

  • AUSTRAC's reforms related resources page - click here

  • AML/CTF Transitional Rules - click here

  • Risk Assessments - click here (includes National and Sectoral risk assessments).

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Compliense Advisors is an AML/CTF and FinCrime compliance and risk management advisory firm. Our experience includes implementing legislative changes; undertaking ML/TF risk assessment; setting up, implementing, uplifting AML/CTF program; and advising on AML/CTF and FinCrime compliance and risk matters.

 

The contents above is for general awareness and informational purposes only. Please carefully evaluate your circumstances, and seek professional advice for your specific needs. You are responsible for your compliance obligations, and for any action taken or omitted. We are not a law firm, and do not provide legal advice.

 

Write to us on compliense@compliense.com.au. Visit here for more such knowledge resources. You can also sign up for new articles and updates
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