On 28 August 2026, AUSTRAC CEO Brendan Thomas warned tranche 2 entities that have not yet enrolled with AUSTRAC that “the time for preparation has passed”, that “if a business is providing designated services, it needs to be enrolled with AUSTRAC and actively managing the risk that criminals could exploit its services to move or hide illicit money”, and that “businesses that ignore the law should expect regulatory scrutiny”.
Which entities are now subject to AML/CTF obligations?
On 1 July 2026, the anti-money laundering and counter-terrorism financing (AML/CTF) reforms drew a number of additional entities (referred to as ‘tranche 2 entities’) into the AML/CTF regime. Those working in relevant sectors, such as real estate agents, accountants, lawyers, conveyancers, trust and company service providers, and jewellers are responsible for assessing the services that their businesses provide to identify whether those businesses are tranche 2 entities and therefore regulated under the AML/CTF regime.
Businesses that appear to be providing designated services but that have not yet enrolled with AUSTRAC can expect to be issued with section 167 notices by AUSTRAC, requisitioning information that will help the regulator determine whether or not those businesses should be enrolled.
What should businesses do to be compliant with the AML/CTF regime?
If you are unsure whether or not your business is regulated under the AML/CTF regime, or would like assistance with the preparation of an AML/CTF Program, please get in touch with Cowell Clarke’s Financial Services & AML/CTF team at Compliance@CowellClarke.com.au.
Richard Beissel and Zac Mizgalski wish to thank Sacha Mutze for her contribution to this insight.
This publication has been prepared for general guidance on matters of interest only and does not constitute professional legal advice. You should not act upon the information contained in this publication without obtaining specific professional legal advice. No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this publication and to the extent permitted by law, Cowell Clarke does not accept or assume any liability, responsibility or duty of care for any consequences of you or anyone else acting or refraining to act in relation on the information contained in this publication or for any decision based on it.