Tranche 2 is the next stage of Australia's AML/CTF regulatory framework, which comes into full effect in 2026. It expands compliance obligations to professions not previously captured under Tranche 1, including lawyers, conveyancers, accountants, and real estate agents involved in property transactions or the handling of client money.

If your firm provides a designated service, you are required to enrol with AUSTRAC, establish a written AML/CTF program, conduct client due diligence, and report certain activity to AUSTRAC on an ongoing basis.

From 2026, all reporting entities under Tranche 2, including conveyancers and property lawyers providing designated services, must be enrolled with AUSTRAC and have an operational AML/CTF compliance framework in place.

AUSTRAC has indicated it does not intend to issue substantial fines during the first year of Tranche 2, however enrolment and a good-faith compliance effort are still required from day one.

AML/CTF stands for Anti-Money Laundering and Counter-Terrorism Financing. The regime requires reporting entities to put in place processes that identify, manage, and report potential money laundering or terrorism financing risk.

In practice, this means verifying your clients' identities, conducting risk assessments, screening clients against PEPs and sanctions lists, and reporting suspicious activity to AUSTRAC when required.

If your firm provides a designated service, yes. For conveyancers and property lawyers, this typically covers property settlement transactions, the preparation or execution of certain legal documents related to property, and the handling of client money or trust accounts in connection with these activities.

Not sure whether your firm is captured? Use our free Designated Services Checker to find out.

Tranche 2 applies broadly to any professional activity that involves handling client money, preparing or executing documents related to property transactions, or managing trust accounts in connection with these services.

For conveyancers, this covers property settlement and transfer work. For lawyers, it extends to property matters, estate planning where property is involved, and commercial transactions that include real property.

Non-compliance with Tranche 2 can result in civil and criminal penalties under the AML/CTF Act, including significant fines. Beyond financial penalties, there is also substantial reputational and regulatory risk for firms found to be operating without an adequate compliance framework.

AUSTRAC has signalled a supportive approach during the first year, with a focus on education over enforcement. However, firms are still expected to be enrolled and making genuine compliance efforts.

Verification of Identity (VOI) is the process of confirming that a client is who they say they are. It is a core requirement under both the existing conveyancing rules and the new AML/CTF framework.

Under Tranche 2, VOI forms part of your Customer Due Diligence (CDD) obligations. triSearch's Compliance Centre includes a VOI workflow that can be completed digitally, with results stored automatically against the matter for audit purposes.

triSearch's Compliance Centre brings together every step of your AML/CTF obligations in one place, integrated directly into your practice management system. It covers enrolment guidance, firm-level risk assessment, policy and program templates, staff training, client onboarding questionnaires, CDD and VOI workflows, suspicious matter and threshold reporting, and automated record keeping.

It was developed in collaboration with Grant Thornton Australia, advisers to AUSTRAC, and is built from the official AUSTRAC Starter Kits. It is complimentary to use — you only pay for the searches you order, just as you do today.

The Compliance Centre includes VOI, a client onboarding questionnaire (pre-filled where possible with smart risk-based logic), PEPs screening, sanctions screening, adverse media checks, and an automatically generated Customer Risk Report. Enhanced Due Diligence options including Verification of Funds are also available where required.

All results are stored against the matter and retained for seven years to meet AUSTRAC's record-keeping requirements.

The Compliance Centre is complimentary. There are no subscription fees, platform fees, or set-up costs. You only pay for the searches and verifications you order, which can be passed on to your clients as a disbursement, just as you do with other searches today.

Yes, in part. If you are already using triSearch's Onboarding and VOI solution, the identity verification workflows you have in place form part of the foundation your AML/CTF compliance program needs. The Compliance Centre builds on what you already have, adding the additional layers required under the new framework including risk assessments, policy templates, reporting, and record keeping.