撰稿人： Savannah Barrios
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2026年3月20日
Australia’s anti-money laundering and counter-terrorism financing (AML/CTF) regime is undergoing significant reform, with the long-anticipated “Tranche 2” reforms set to reshape the regulatory landscape. What Are the Tranche 2 Reforms? Since the introduction of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, Australia’s AML/CTF regime has applied primarily to financial institutions, gambling providers and certain remittance services. Tranche 2 reforms will extend these obligations to additional high-risk sectors, including legal practitioners, accountants, trust and company service providers, real estate professionals and dealers in precious metals and stones. Key Compliance Obligations Entities newly captured under Tranche 2 will be required to: Enrol and register with AUSTRAC from 31 March 2026. Develop and maintain a compliant AML/CTF Program before 1 July 2026. Undertake customer due diligence (CDD), including identification and verification of clients and beneficial owners. Conduct ongoing customer monitoring. Report suspicious matters, threshold transactions and annual reports on an ongoing basis; and Maintain appropriate records and governance controls. Increased Regulatory Scrutiny and Enforcement AUSTRAC has demonstrated a willingness to take strong enforcement action against non compliant entities in recent years. With the expansion of the regime, newly regulated sectors can expect heightened supervisory engagement, including audits and enforcement proceedings where serious deficiencies are identified. Preparing for the Transition Although transitional periods are anticipated, affected businesses should begin preparing now. Early action may include conducting preliminary risk assessments, mapping services against designated activities, reviewing client onboarding procedures, and engaging external advisors to assist with program design and implementation. The Tranche 2 reforms represent one of the most recent substantial expansions of Australia’s financial crime regulatory framework. For many organisations, compliance will not simply be a box-ticking exercise, but a fundamental operational adjustment. How Can We Help? At CJM Lawyers, we have been closely monitoring the evolving AML/CTF regime for years through our experience in advising Tranche 1 entities of their compliance obligations. Our team can assist with risk assessments, AML/CTF program development, governance reviews, and regulatory engagement to ensure your organisation remains compliant. In a rapidly changing legal and regulatory landscape, proactive and ongoing advice is essential — and we are here to help you stay regulated, protected and prepared. Arrange for a meeting with a member of our experienced regulatory compliance team to see how we can help you navigate this new area with confidence.
