The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 (Act No. 110 of 2024) passed the Australian Parliament on 29 November 2024 — the legislative vehicle behind Tranche 2, extending AML/CTF obligations to a group of professions that had sat outside the regime since the original AML/CTF Act 2006.
What did the Amendment Act actually change?
Two things, structurally. It expanded the regime to cover Tranche 2 entities — lawyers, accountants, real estate agents, trust and company service providers, and dealers in precious metals and stones — who now carry the same core AML/CTF obligations banks and financial institutions have operated under for years. And it modernised parts of the regulatory framework itself, aiming to simplify compliance requirements and account for digital business practices and financial technologies the original 2006 Act didn't anticipate.
What obligations does the Act actually impose on Tranche 2 entities?
Enrolment with AUSTRAC as a reporting entity. Customer due diligence at onboarding and on an ongoing basis. Monitoring of transactions and business relationships, not just a point-in-time check. A written, business-specific AML/CTF programme — not a generic template. Suspicious matter and threshold transaction reporting. And record-keeping across customer due diligence, monitoring outcomes, and every compliance action taken.
Why did Australia need this reform specifically?
To align with Financial Action Task Force global standards, which have long expected countries to regulate designated non-financial businesses and professions alongside the financial sector proper. Australia's gap here had been identified and flagged for years before the Amendment Act closed it — bringing the country into closer alignment with jurisdictions like the UK, EU, and Singapore that already regulate similar sectors.
Where do things stand now?
AUSTRAC enrolment was required from 31 March 2026, with the Act's obligations taking full effect from 1 July 2026 — both dates have now passed. For the sectors this Act covers, Tranche 2 is no longer a forthcoming reform to prepare for; it's the regulatory standard AUSTRAC now expects to see in practice. See the sector-specific detail for lawyers, accountants, real estate professionals, precious metals dealers, and trust and company service providers, or build a risk-based AML programme that meets Tranche 2 obligations for the practical next step.
