AML/CTF for new entrants

From 1 July 2026, anti-money laundering and counter-terrorism financing (AML/CTF) obligations will apply to the following professions and businesses (Tranche 2 businesses):

• Real estate professionals including real estate agents, buyers agents and property developers
• Professional service providers such as lawyers, accountants, conveyancers and trust company service providers
• Dealers in precious stones, metals and products.

Key obligations for new Tranche 2 entities regulated by AUSTRAC

• Enrol with AUSTRAC.
• Undertake a risk assessment to identify and assess your ML/TF risk.
• Develop and maintain an AML/CTF program tailored to your business that mitigates and manages your ML/TF risk.
• Conduct initial and ongoing customer due diligence.
• Report certain transactions and suspicious activities to AUSTRAC.
• Make and keep records.

What AML/CTF obligations apply to Tranche 2 businesses?

For real estate professionals

• Brokering the sale, purchase, or transfer of real estate on behalf of clients.
• Selling or transferring real estate without an independent real estate agent, such as property developers selling house and land packages, apartments off the plan, and blocks of vacant land in new subdivisions.

For professional services providers

• Assisting in planning or executing transactions involving the buying, selling, or transferring of real estate, a body corporate or legal arrangement.
• Receiving, holding and controlling or managing client’s money, accounts, securities, securities or virtual assets in the planning and execution of a transaction.
• Assisting a person in organising, planning or executing a transaction for equity or debt financing that relates to a body corporate or legal arrangement.
• Selling or transferring shelf companies.
• Formation, creation, or management of legal entities for clients.
• Acting as, or arranging for, another person to act as a director or secretary of a company, power of attorney or shareholder of a body corporate or legal arrangement, partner in a partnership or trustee of an express trust.
• Providing a registered office or principal place of business address of a body corporate or legal arrangement.

For dealers in precious stones, metals and products

• Buying, selling, or dealing in precious stones, metals, and related products.
• Accepting cash and/or virtual assets valued at $10,000 or more when purchasing or selling precious metals, precious stones, and precious products.

Resources for Tranche 2 entities

Access curated resources relevant to Tranche 2 entities on the KordaMentha AML/CTF Hub. As changes roll out, we will be updating our resource library to support new entrants in becoming AML compliant.

We strongly encourage you to subscribe to receive updates and be the first to hear of upcoming webinars, milestones and other downloadable AML/CTF compliance resources.

Senate Submission

AML/CTF Amendment Bill Senate submission

KordaMentha was invited to make a submission to the Legal and Constitutional Affairs Legislation Committee inquiry into the Anti-Money Laundering and Counter-Terrorism Financing Amendment Bill 2024.

Service Brochure

AML as a managed service

We offer AML as a Managed Service, a fully customisable, onshore end-to-end AML solution that enables the secure and cost-effective management of your AML/CTF compliance obligations.

Bulletin

AML/CTF reforms for the real estate industry

Understand how the AML/CTF reforms specifically impact the real estate industry. This bulletin explains the breadth of the reforms and the obligations for real estate agents under these upcoming changes.

Justice Committee submission

New Zealand Justice Committee submission

KordaMentha was invited to make a submission to the Justice Committee inquiry into the Anti-Money Laundering and Counter Financing of Terrorism Amendment Bill before the New Zealand parliament.

Bulletin

AML/CTF reforms for professional services

Professional services providers including lawyers, accountants, conveyancers, and trust and company service providers will be captured under Australia’s AML/CTF regime for the first time. Learn what this means for your business and understand your new obligations as a professional services firm in this bulletin.

Our client impact

Independent review of Australian superannuation organisation 

Financial Crime Risk & Compliance

KordaMentha was engaged by an Australian superannuation business to conduct a comprehensive review of its Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Program.

View full case study