AML compliance professional services

Tranche 2 AML/CTF Reforms – Why AML Compliance Matters for Professional Services

From 1 July 2026, the long-anticipated “Tranche 2” reforms to Australia’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) regime will come into effect. These reforms extend AUSTRAC’s regulatory net to include professional service providers such as lawyers, accountants, conveyancers, and real estate agents. For many, this marks the beginning of a new era of AML compliance for professional services.

For the first time, these “gatekeeper” professions will face obligations previously reserved for banks and financial institutions. The policy intent is clear: professionals who move money, property, or assets are often at the front line of financial crime risks. The reforms are designed to close gaps in Australia’s defences against money laundering and terrorism financing.

What the reforms mean in practice

Under Tranche 2, affected firms will need to:

• Conduct customer due diligence (CDD), including verification of identity (VOI) and ongoing monitoring.
• Establish internal AML/CTF compliance programs with clear policies, controls, and procedures.
• Report suspicious matters (SMRs), threshold transactions, and international fund transfers.
• Maintain accurate, audit-ready records for at least seven years. 
• Train staff and demonstrate AML compliance readiness to AUSTRAC.
   

While these obligations may sound daunting, they are based on familiar principles: risk-based compliance, governance oversight, and transparent recordkeeping. The challenge for professional firms lies in embedding these requirements into daily practice without disrupting client service—making AML compliance technology solutions essential for efficiency.

Why preparation matters

Firms that treat compliance as a last-minute exercise will struggle. Tranche 2 requires more than a written policy—it requires cultural adoption. Staff must be trained to identify red flags, leaders must demonstrate oversight, and systems must generate reliable, auditable records.

For many small and mid-sized firms, the resource burden will feel significant. But those who prepare early will not only reduce regulatory risk, they may also find compliance brings benefits: stronger governance, better data management, and increased confidence when facing both clients and regulators.

How we can help

At Rolf Howard Consulting, we have been preparing firms for Tranche 2 AML compliance well ahead of time. Our services include:

• Designing AML compliance frameworks aligned with AUSTRAC’s expectations. 
• Developing practical templates, checklists, and reporting structures that can be adopted immediately.
• Advising boards and business owners on governance-first approaches that integrate compliance with growth strategies.
• Recommending AML compliance technology solutions, such as digital onboarding and recordkeeping systems, that lower costs while improving accuracy.
   

With over 35 years of legal and business leadership, and as Certified Anti-Money Laundering Specialists (CAMS), our team understands both the regulatory landscape and the operational realities that AML compliance professional services face.

Final thoughts

Tranche 2 is not just a regulatory hurdle—it is an opportunity for professional firms to strengthen governance, improve culture, and build client trust. By investing early in AML compliance technology solutions and practical frameworks, firms can avoid disruption and turn compliance into a long-term advantage.