Understanding the Upcoming Tranche 2 AML/CTF Reforms
From 1 July 2026, important changes to Australia’s Anti-Money Laundering and Counter-Terrorism Financing regime will come into effect.
These reforms, commonly referred to as “Tranche 2”, will expand the existing AML/CTF framework to include a wider range of professional services, including certain services provided by accountants, lawyers, real estate professionals and trust and company service providers.
For many clients, these changes will have little to no impact on day-to-day dealings with us. However, for certain types of engagements, there may be additional identity verification and information-gathering requirements before we can commence work.
Why are these changes being introduced?
The purpose of the AML/CTF regime is to help prevent professional services from being misused for money laundering, terrorism financing or other forms of financial crime.
The expansion of the regime reflects a broader global effort to strengthen the integrity of the financial system and ensure that businesses involved in high-risk professional services have appropriate processes in place to identify and manage potential risks.
What types of services may be affected?
The new requirements may apply when we assist with certain engagements, such as:
Establishing or restructuring companies, trusts or other entities
Assisting with corporate transactions
Acting in formal roles on behalf of a client
Providing services connected to business structures, ownership or control
Supporting matters where additional due diligence may be required
These requirements will not apply to every service we provide. Whether additional checks are required will depend on the nature of the engagement and the specific work being undertaken.
What information may we need from you?
Where the new requirements apply, we may need to verify your identity and, where relevant, the identity of individuals who own, control or make decisions for your business or structure.
Depending on your circumstances, we may ask for:
Current photo identification, such as a passport or driver’s licence
Details of your business structure, including directors, trustees or significant shareholders
Information about beneficial owners or controlling parties
Additional information about the nature of a transaction or engagement
Supporting documentation to keep our client records accurate and up to date
In some cases, we may also be required to perform more detailed checks in relation to the nature of a transaction or the source of funds.
What does this mean for existing clients?
For most clients, there is no immediate action required.
We are currently updating our internal systems and processes to ensure we meet the new obligations while keeping any additional administration as simple and efficient as possible.
If we need updated information or documentation from you, we will contact you directly and clearly explain what is required.
Our commitment to making this process as smooth as possible
We understand that additional compliance steps can be inconvenient. Our priority is to manage these changes in a practical and streamlined way, while continuing to provide the same level of service and support you expect from our team.
These changes are part of a wider regulatory shift across Australia’s professional services sector. By preparing early, we can help ensure a smooth transition for our clients and our team.
Need guidance on what this means for you?
At this stage, you do not need to take any action unless we contact you directly.
However, if you have questions about how the upcoming AML/CTF changes may affect your business, structure or future engagements, our team is here to help. Speak with our team today to understand what these changes may mean for your specific circumstances.