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DO I NEED TO COMPLY?

For years, Anti-Money Laundering (AML) laws only applied to big banks and casinos. But with the 2026 Tranche 2 reforms, the net has widened.

Compliance is no longer just for the financial sector—it now applies to professionals who facilitate high-value transactions, manage client funds, or set up corporate structures. If you work in real estate, law, or accounting, the answer to "Do I need to comply?" is almost certainly yes. If you provide a "designated service," you are legally required to enrol with AUSTRAC and have a compliant program in place.

Image by Romain Dancre
The BUSINESS TEST: TRANCHE 2 TRIGGERS​​


Under the expanded Anti-Money Laundering and Counter-Terrorism Financing Act 2006, you are classified as a Reporting Entity if you provide any of the following "designated services" in the course of your business. If you trigger any of these categories, you are legally required to enrol with AUSTRAC and implement a compliance program.

 

REAL ESTATE PROFESSIONALS
 

  • Acting as an agent in the brokering, buying, or selling of real estate.

  • Selling property as a developer (including off-the-plan apartments, house and land packages, and vacant land subdivisions).
     

LAWYERS & CONVEYANCERS
 

  • Managing client funds, trust accounts, or securities.

  • Acting in conveyancing or settlements for the buying or selling of real estate or business assets.

  • Creating, operating, or restructuring companies, trusts, or legal arrangements.
     

ACCOUNTANTS & ADVISORS
 

  • Receiving, holding, controlling, or managing a client's property or funds to help execute a transaction.

  • Providing high-level assistance in the planning or execution of corporate restructuring or entity creation.


TRUST & COMPANY SERVICE PROVIDERS

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  • Acting (or arranging for someone to act) as a nominee director, nominee shareholder, or partner in a partnership.

  • Providing a registered office or principal business address for a corporate entity.
     

The Geographical Link These obligations apply if the designated service is provided at or through a permanent establishment in Australia, or by an Australian resident entity.

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