Obligations Overview

Tranche 2 brought a second wave of industries into Australia's AML/CTF regime. From 1 July 2026, accountants, real estate agents, lawyers, conveyancers, jewellers and dealers in precious metals and stones have obligations they did not have before.

Obligations come from providing a service the law covers, not from being in one of those industries.

To check your own services, use Am I in scope?.

The test is the service you provide

Obligations attach to a designated service. A firm becomes a reporting entity when it provides one as part of its business, even if it does so only once, and even if it does so without charging.

A firm that provides none of the listed services has no AML/CTF obligations, whatever its profession.

The services are set out in s 6 of the AML/CTF Act 2006 across six tables. Three apply to the firms this knowledge base covers:

Table	Covers
Table 2	Bullion and precious metals, stones and products
Table 5	Real estate services
Table 6	Professional services, nine items, profession neutral

Table 1 covers financial services, including virtual asset services. Table 3 covers gambling services, and Table 4 covers services prescribed by regulation. None of these are relevant to the five verticals this knowledge base covers.

Table 6 is deliberately profession neutral: capture follows the service, not the job title. A financial adviser who takes instructions to draft a trust deed is providing a listed service, because drafting the deed creates the trust. A solicitor who only advises on the legal effect of a clause is not, because advice can influence a transaction without advancing it.

Two halves to the test

What: is the service on the list? When: has the firm started providing it? A firm starts when it acts on instructions and there is a real transaction to advance. General advice given before that point is not the service.

Which verticals are captured, and by what

Table 6. Accounting work is captured only through the professional services items. Preparing and lodging a tax return, or giving tax advice, is not on the list. Creating or restructuring an entity (item 6), selling or transferring a shelf company (item 5), managing client money to help a transaction (item 3), arranging financing (item 4), and providing a registered office address (item 9) are.

Table 5. Item 1 is brokering the sale, purchase or transfer of real estate. Item 2 is a business selling or transferring its own real estate without an independent agent, such as a developer. Property management and leasing are not designated services. Real estate sits in its own table, and the delayed customer due diligence window keys off that table.

Table 6. Legal practices face a dual service model. Conveyancing is item 1; other captured work is items 2 to 9. The two groups carry different customer due diligence timing, because delayed verification is available for item 1 buyer work. Items 1 and 2 do not apply where the transaction results from a court or tribunal order.

Table 6, items 1 and 2. Conveyancers share the legal structure with a narrower scope: conveyancing, and transactions involving a body corporate or other legal arrangement.

Table 2, item 2. Buying or selling precious metals, stones or products for physical currency or virtual assets totalling $10,000 or more, including linked transactions. Cash deals also bring threshold reporting into play alongside customer due diligence.

The two dates

Date	What happened
31 March 2026	AUSTRAC enrolment opened for Tranche 2 entities
1 July 2026	The obligations themselves commenced

By the second date, every designated service a firm provides must be covered by an AML/CTF program.

What the obligations are

Eight standing obligations run through the regime. Each has its own page under this section.

Obligation	What it requires
Enrol with AUSTRAC	Register as a reporting entity
Build your program	Hold an ML/TF risk assessment and AML/CTF policies
Appoint your AMLCO	Designate an AML/CTF Compliance Officer
Customer due diligence	Identify and verify customers, and assess their risk
Reporting	Report threshold, cross-border and suspicious matters
Record keeping	Retain records, generally for seven years
Staff training	Train staff, and keep the records
Review and evaluation	Review the program, and have it independently evaluated

Order and deadlines

The law requires your AML/CTF policies to be in place before you start offering a captured service (s 26F(8)). You can designate your AML/CTF Compliance Officer up to 28 days after you start (s 26K(1)), and a senior manager approves the program (s 26P(1)). Customer checks need a program that says how to run them. Duely adds one rule of its own: it blocks approval until an officer is appointed. Where a statutory deadline applies, the obligation page states it.

Two product boundaries

• Duely prepares reports and the firm lodges them. Duely produces the report record and, for suspicious matters, the AUSTRAC XML. The firm lodges with AUSTRAC.
• Duely monitors at customer level. It runs ongoing customer monitoring and does not watch a feed of transactions.