AUSTRAC Tranche 2 AML/CTF Obligations (2026)
Under Tranche 2 reforms, lawyers and legal practices involved in financial transactions, trust accounts, conveyancing, or client fund management are now captured under the AML/CTF Act. This page explains exactly what you must do to comply.
Learn more in the AML/CTF Guide.
You are captured if you provide any **designated service**, including:
Managing trust accounts or client funds
Conducting conveyancing or property settlements
Handling payments, transfers, or financial transactions
Acting as an intermediary in financial dealings
Providing services involving high‑risk clients or jurisdictions
Assisting with company or trust formation
If you perform any of these activities, you must comply with the AML/CTF Act — regardless of firm size.
You must maintain a written AML/CTF Programme outlining governance, risk assessment, controls, and CDD procedures.
You must assess the money laundering and terrorism financing risks associated with your clients, matters, and services.
You must verify client identity, understand the purpose of the matter, and apply enhanced due diligence for high‑risk clients.
You must report suspicious matters to AUSTRAC within 3 business days (or 24 hours for terrorism‑related matters).
You must keep AML/CTF records, CDD evidence, and SMR logs for at least 7 years.
You must monitor client activity, update risk assessments, and review your AML/CTF Programme annually.
See full requirements in the AML/CTF Guide.
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