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AUSTRAC Tranche 2 starts 1 July 2026
For the first time, real estate agents, accountants, lawyers, and conveyancers face formal AML/CTF obligations. The question isn't whether to comply — it's whether you can demonstrate that you did.
1 July 2026. AUSTRAC Tranche 2 obligations commence. Real estate agents, accountants, lawyers, conveyancers, and trust and company service providers must have a compliant AML/CTF programme operational. Penalties for non-compliance are up to $22.2 million per contravention for corporate entities.
Newly regulated entities in Australia
Obligation commencement date
Maximum civil penalty per contravention
What Tranche 2 actually requires
The AML/CTF Amendment Act 2024 extends obligations that have applied to banks and financial institutions for over a decade to a broad range of professional services previously unregulated under AUSTRAC. The obligation is not simply to perform checks — it is to operate a documented compliance programme that AUSTRAC can examine at any time and find operating effectively.
- ✓Documented AML/CTF programme. A formal written programme describing your methodology, risk assessment approach, customer identification procedures, and how the programme is reviewed and updated.
- ✓Customer identification and KYC. Verifying the identity of customers before and during the business relationship, using risk-appropriate methods, with documented evidence of every verification step.
- ✓Risk-based Customer Due Diligence. Understanding the nature and purpose of each customer relationship, applying enhanced scrutiny to higher-risk customers, and reviewing that assessment on an ongoing basis — with the reasoning documented for every customer.
- ✓PEP and sanctions screening. Screening customers against Politically Exposed Person registers and sanctions lists, with documented results and a process for handling matches.
- ✓Beneficial ownership. Identifying and verifying the ultimate beneficial owners of corporate customers, trusts, and complex structures.
- ✓Ongoing monitoring. Continuously monitoring customer relationships and transactions for unusual activity, keeping customer information current, reviewing CDD on a risk-based frequency.
- ✓AUSTRAC reporting. Suspicious Matter Reports (SMRs) and Threshold Transaction Reports (TTRs) submitted to AUSTRAC, along with annual compliance reporting and enrolment.
- ✓Staff training. Documented training programme covering AML/CTF obligations, red flags, and escalation procedures.
The most important thing to understand about Tranche 2: AUSTRAC's standard is not "did you try?" It is "can you prove it?" Every check, every decision, every escalation needs to be documented. A compliance programme that runs checks but doesn't produce records will not satisfy an AUSTRAC examination.
Not sure where your programme currently stands? Synalogic can help you assess your Tranche 2 readiness and map a path to compliance before July 2026.
Who is captured under Tranche 2
Real estate agents
Sales, leasing, and property management. Any agent facilitating the buying, selling, or leasing of real estate. Franchise networks must implement a consistent programme across all offices.
Accountants and tax agents
Tax planning and compliance, bookkeeping, company formation, financial management, and related financial advisory services. The obligation attaches to the designated service, not the firm's primary sector.
Lawyers and conveyancers
Property transactions, commercial transactions, trust and company services, asset management, and related legal services. Legal professional privilege does not exempt firms from AML/CTF obligations.
Trust and company service providers
Entities that form companies, act as registered agents, provide registered office services, or act as trustee or nominee. These services carry elevated risk and attract enhanced CDD requirements.
How Synalogic AML/CTF Compliance delivers the programme — and the proof
Most KYC tools handle identity verification. That is one part of the obligation. Synalogic AML/CTF Compliance covers the complete AML/CTF programme — from onboarding to ongoing monitoring to AUSTRAC reporting — with a documented compliance trail at every step.
- ✓AI-assisted KYC and identity verification. Structured workflows with AI-assisted document review. Every step recorded with evidence, reviewer attribution, and timestamp. New customers onboarded in minutes; returning customers through in seconds.
- ✓Risk-based CDD classification. Automatic CDD level assignment — Standard, Enhanced, Simplified — based on your risk methodology, with reasoning documented for every customer.
- ✓PEP and sanctions screening. Automated screening against PEP registers and global sanctions lists at onboarding and daily monitoring against your active customer database. Results documented with human review sign-off.
- ✓Beneficial ownership mapping. Complex structures — trusts, companies, partnerships — visually mapped and verified at each ownership layer.
- ✓Ongoing review scheduling. Risk-based CDD review frequency automated. Overdue reviews escalated to the appropriate officer. Nothing falls through.
- ✓AUSTRAC-ready reporting. TTRs, SMRs, and enrolment formatted to AUSTRAC requirements. Compliance reports for internal governance and board reporting. FATF-aligned.
For single offices and small firms
Simple onboarding, guided setup, full programme operational within weeks. Designed for small-team reality — one person can hold all compliance roles with separate timestamped approval steps.
For franchise networks and large groups
One platform across all offices. Consolidated group compliance view. Franchise compliance managers oversee the programme at network level while individual offices manage their own queues.
Common questions
Questions from real estate agents, accountants, and lawyers navigating Tranche 2.
What is AUSTRAC Tranche 2 and who does it apply to?
AUSTRAC Tranche 2 refers to the AML/CTF Amendment Act 2024, which for the first time extends formal AML/CTF obligations to real estate agents, accountants, lawyers, conveyancers, and trust and company service providers. Obligations commence on 1 July 2026 for most regulated entities.
What does a compliant AML/CTF programme need to include?
A compliant programme must include: a documented AML/CTF programme; customer identification and KYC; risk-based CDD including enhanced scrutiny for higher-risk customers; PEP and sanctions screening; ongoing monitoring; SMR and TTR reporting to AUSTRAC; staff training; and record-keeping. Critically, the obligation is not just to perform these checks — it is to be able to demonstrate to AUSTRAC that the controls are operating effectively.
What KYC software is best for real estate agents in Australia?
The best KYC software for Australian real estate agents under Tranche 2 covers the full compliance workflow, not just identity verification. Synalogic AML/CTF Compliance covers all elements: AI-assisted document review, risk-based CDD, PEP and sanctions screening, beneficial ownership capture, ongoing monitoring, and AUSTRAC-ready reporting including SMRs and TTRs. Unlike point solutions, AML/CTF Compliance provides the complete programme with the documented audit trail AUSTRAC requires.
What is the difference between KYC and CDD?
KYC refers to identity verification — confirming a customer is who they say they are. CDD is broader: understanding the nature and purpose of the customer relationship, assessing the risk it presents, applying enhanced scrutiny to higher-risk customers, and reviewing that assessment on an ongoing basis. KYC is the foundation of CDD. Under AUSTRAC Tranche 2, regulated entities must perform both and document the methodology and outcomes.
What are the penalties for not complying with Tranche 2?
AUSTRAC has civil penalty powers of up to $22.2 million per contravention for body corporates and $4.44 million for individuals. Criminal penalties for serious or wilful non-compliance are also available. AUSTRAC can issue remedial directions and publicise enforcement action. For professional services firms, enforcement action also creates reputational and professional indemnity consequences.
How long does it take to implement an AML/CTF programme?
For a single-office or small firm using Synalogic AML/CTF Compliance, implementation can be completed in weeks with guided onboarding. For larger franchise networks, Synalogic offers deployment packages including operating model design, staff training, and managed service options. With the July 2026 deadline approaching, organisations that have not yet begun should move promptly — a compliant programme requires design, configuration, training, and testing, all of which take time.
The deadline is real. The programme doesn't have to be hard.
Synalogic AML/CTF Compliance delivers a complete, documented AML/CTF programme for newly regulated entities — from customer identification to AUSTRAC reporting. Talk to us about getting your programme operational before 1 July 2026.