A accountant's guide to navigating Tranche 2 reforms

AML/CTF Tranche 2 reforms for accounting

What is Tranche 2 of the AML/CTF reform?

The AML/CTF Act 2006 has historically applied to financial institutions and high-cash industries such as casinos, remittance services and bullion dealers. Entities providing designated services, like deposit-taking, payroll and currency exchange, must comply, including reporting threshold transactions and suspicious activity.

On 29 November 2024, the AML/CTF Amendment Bill (Tranche 2) passed the House of Representatives, extending the regime to the legal, accounting and real estate sectors.

On 29 August 2025, AUSTRAC tabled the new AML/CTF Rules 2025 in Parliament, following a two-stage public consultation. The Rules, published on the Federal Register of Legislation with an Explanatory Statement, set out how they work with the amended AML/CTF Act 2006 and what reporting entities must do to be compliant.

For accounting professionals, compliance is not only a statutory obligation but also a safeguard against facilitating financial crime and a means of maintaining professional integrity and client trust.

Understanding AML/CTF Rules 2025

The AML/CTF Rules 2025 runs to 120+ pages of legalese, obligations, definitions and reporting detail. First AML's compliance team have done the heavy lifting: translated it into plain English, added real-world examples and highlighted what matters for the accounting sector.

AML/CTF Rules 2025: Reporting groups

The layman's guide to AML/CTF Rules 2025: Part 2 - Reporting groups

Learn how reporting groups work under Part 2 of the AML/CTF Rules 2025. Understand business groups, elected reporting groups, lead entity requirements, and compliance obligations.
AML/CTF Rules 2025: An overview

AML/CTF Rules 2025: A plain-English overview for busy professionals

Plain-English guide to Australia’s AML/CTF Rules 2025 for Tranche 2 entities: enrolment, reporting groups, CDD, AML programs, and key obligations.
AML/CTF Rules 2025: Part 2 - Reporting groups

AML/CTF Rules 2025: Reporting groups for accounting

From July 2026, Australian accounting firms must comply with AML/CTF obligations. Learn how reporting groups work, what they mean for accountants, and the steps to prepare.
AML/CTF Rules 2025: Part 3 - Enrolment

The layman's guide to AML/CTF Rules 2025: Part 3 - Enrolment

Learn how businesses can enrol with AUSTRAC for AML/CTF compliance. Understand what service, business, group, and financial details you need to provide and how to keep your information up to date.
AML/CTF rules 2025: AML/CTF programs

The layman's guide to AML/CTF Rules 2025: Part 5 - AML/CTF programs

Part 5 of the AML/CTF Rules explains how to build a compliant program, covering risk assessments, CDD, PEP approvals, audits, reporting, and record-keeping.
AML/CTF Rules 2025: Part 3 - Enrolment

AML/CTF Rules 2025: Enrolment for accounting

From 31 March 2026, accounting firms providing designated services under the AML/CTF Act must enrol with AUSTRAC. Learn what enrolment involves, key requirements, and how to prepare for compliance.
AML/CTF rules 2025: AML/CTF programs

AML/CTF Rules 2025: AML/CTF programs for accounting

AML/CTF programs will reshape how accounting practices onboard clients, manage risk and report to AUSTRAC. Learn the core requirements and what to prepare for 2026.
AML /CTF Rules 2025: Part 6 - Customer due diligence

The layman's guide to AML/CTF Rules 2025: Part 6 - Customer due diligence

Part 6 of the AML/CTF Rules. Learn what customer due diligence means, from ID checks and beneficial ownership to ongoing monitoring, enhanced checks, and record-keeping.
AML/CTF Rules 2025 Part 9 - reporting

The layman's guide to AML/CTF Rules 2025: Part 9 - Reporting

Understand AUSTRAC’s reporting rules: when to file Suspicious Matter Reports, Threshold Transaction Reports and annual AML/CTF compliance reports.
AML/CTF Rules 2025 Part 9 - reporting

AML/CTF Rules 2025: Reporting for accounting

From 1 July 2026, Australian accounting firms must lodge SMRs, TTRs in certain situations, and annual AML/CTF compliance reports with AUSTRAC. Here's what you need to do and when.

Tranche 2 guidance

Once your business is registered, you are a "reporting entity" and need to keep up with your obligations under the Act. These quick guides aim to help you fulfil your compliance obligations.

Short hair woman with glasses looking at monitor screen

A step-by-step guide to creating an AML/CTF program

Learn how to create a compliant AML/CTF program under Australia’s AML/CTF Act to prevent financial crime and meet AUSTRAC regulations.
Passporting AML

Reporting groups for law and accounting firms

AML falls under three operating models; centralised, de-centralised and hybrid. Each has its own pros and cons with unique impacts on business operations and AML effectiveness. Find out which model is right for you.

Helpful links

AML/CTF bill and rules

FATF guidance

Governmental

Industry

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