On 31 March 2026 AUSTRAC opened enrolment for the professions newly regulated under the “Tranche 2” anti-money laundering reforms: accountants, lawyers, conveyancers, real estate professionals and dealers in precious stones and metals. If you work in one of these fields, this is not a development to file under “big end of town”. Tens of thousands of small professional services and real estate firms are becoming AUSTRAC reporting entities; the obligations land soon.
The two dates that matter
- Full AML/CTF obligations apply from 1 July 2026
- Newly regulated entities must enrol with AUSTRAC by 29 July 2026
Read those dates together and the message is clear: the enrolment deadline falls after your obligations have already started. Enrolling in late July does not buy you a late start on compliance. Details of the enrolment opening are in AUSTRAC’s announcement.
What the obligations broadly involve
For a newly captured firm, the regime comes down to six things:
- Enrolling with AUSTRAC
- Appointing a compliance officer
- Carrying out a money laundering and terrorism financing risk assessment for your business
- Having an AML/CTF program
- Conducting customer due diligence
- Reporting certain transactions and suspicious matters
None of these is exotic for firms used to professional standards, but together they are a genuine body of work. The risk assessment in particular is foundational; your program is meant to respond to the risks you identify, so it cannot be left until last.
Small does not mean exempt
A common assumption in small firms is that regimes like this are calibrated for large institutions and will somehow not apply at their scale. That assumption is wrong here. Capture depends on the services you provide, not on headcount or turnover. A two-partner accounting practice, a suburban conveyancer or a single-office real estate agency can each be a reporting entity.
AUSTRAC clearly anticipates this, because it has released a starter kit aimed at small accounting firms with 15 staff or fewer. If that describes your practice, the starter kit is the obvious first read.
What to do now
- Confirm whether your services are captured. Work through this properly rather than assuming an answer in either direction
- Enrol early rather than at the 29 July deadline. Enrolment is the easy step; getting it done removes one moving part
- Start your money laundering and terrorism financing risk assessment now, because the program that follows depends on it
- Use AUSTRAC’s small-firm starter kit if you are an accounting practice with 15 staff or fewer
- Get advice if your situation is unclear. Boundary cases exist; a wrong guess in either direction is expensive: unnecessary compliance cost one way, regulatory exposure the other
A note for our professional clients
Many of the firms we work alongside, accountants and real estate professionals especially, are captured by this change. If that is you, treat the next three months as the window to stand up your program calmly. The firms that wait for July will be competing for the same scarce advisers at the same time.
Before you act
This article is general information only and is not legal advice. Whether your services are captured and what your program needs to contain are legal questions about your specific circumstances. Confirm your position with a lawyer or check the official AUSTRAC guidance before acting.