Most Tranche 2 guidance is written for firms that already understand AML. This is written for firms that do not, because the businesses brought into the regime had never been reporting entities and had no existing programme to extend.
The sequence divides into two unequal halves. Four things are done once and had deadlines attached. Two continue indefinitely, have no completion date, and carry almost all of the ongoing cost.
Scope is decided service by service
The obligations attach to designated services rather than to an industry. AUSTRAC's newly regulated categories cover real estate, professional services, precious metals and stones, and virtual assets, but membership of one of those sectors is the beginning of the question rather than the answer.
Two firms with identical shopfronts can land on opposite sides of the line depending on what they actually do for clients. That makes scope the first piece of work, and getting it wrong invalidates everything built on top.
The dates have passed, which changes what matters
Enrolment with AUSTRAC opened on 31 March 2026, obligations for the newly regulated sectors commenced on 1 July 2026, and the enrolment deadline was 29 July 2026. Obligations for new virtual asset services, including travel rule requirements, commenced on the same 1 July date.
So the sequence below is no longer a preparation plan. For a firm already inside the regime it is a checklist against what should exist, and the emphasis has moved to the two ongoing obligations at the end, because those are what supervision examines once a regime has bedded in. For a firm that has not enrolled, the sequence still holds, and the first step is the one that matters most: establish scope and write down the reasoning, with a date on it.
The existing book is the real work
A new intake process is straightforward: it applies from a date, to people who are not yet clients. The harder problem is the relationships already on the file, opened under no AML standard at all, where the firm now has to establish who the client is and what risk they present.
For a law firm or an agency with long-standing clients, that is a conversation as much as a system exercise, and it is why the transitional period runs for three years rather than three months.
Reporting is a new muscle
Suspicious matter reporting has its own timeframes and a tipping-off prohibition attached, meaning a firm can be obliged to report a client without telling them. For professional service firms in particular, that sits awkwardly beside existing client duties and needs to be worked through before the first case arrives rather than during it.
What supervision will look at
Supervision follows commencement rather than arriving with it. When it does, the question is not whether a programme exists on the day of the review. It is what the record shows from the first day of the regime.
That argues for evidence discipline from the start, which is cheap on day one and expensive to reconstruct later.
For what Tranche 2 is and what it means sector by sector, see the Tranche 2 blog cluster. For the components, see AML risk assessment, PEP and sanctions screening and enhanced due diligence.