For almost two decades, Australia’s anti-money laundering laws largely stopped at the bank counter, leaving out the lawyers, accountants and agents who facilitate many large transactions. That changed on 1 July 2026, when the long-promised “tranche 2” reforms brought tens of thousands of real estate agents, lawyers, conveyancers, accountants, trust and company service providers, and dealers in precious metals and stones under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006.

Four months in, the financial intelligence agency AUSTRAC has made clear the grace period is over.

The first infringement notices

On 30 September 2026, AUSTRAC announced it had begun issuing infringement notices to businesses in the real estate, accounting and jewellery sectors that it believes failed to enrol within 28 days of first providing a designated service. The notices were issued at $21,840 for companies and $4,368 for individuals, and AUSTRAC said they can accrue daily.

The enforcement followed formal requests for information that AUSTRAC sent in August to businesses that appeared to be providing designated services without having enrolled. Chief executive Brendan Thomas said that around 90% of an initial group of businesses of concern had since enrolled or tried to, and that AUSTRAC would issue more notices where necessary.

For most newly regulated businesses, the enrolment deadline was 29 July 2026.

Who is caught

The reforms, legislated by the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024, regulate particular services, not entire professions. For lawyers, accountants and other professional advisers, AUSTRAC’s guidance lists designated services that include:

  • assisting in planning or executing the sale, purchase or transfer of real estate, or of a company or other legal arrangement
  • receiving, holding or managing a client’s money or property as part of a transaction
  • assisting with equity or debt financing for a company or legal arrangement
  • creating or restructuring companies, trusts and other structures, and selling shelf companies
  • acting as, or arranging for someone to act as, a director, secretary, trustee or nominee shareholder
  • providing a registered office or principal place of business address.

Real estate agents, buyer’s agents and property developers are captured for certain property transactions. Some exemptions apply, for example for legal aid commissions and community legal centres.

What the obligations look like

Enrolment is only the first step. From 1 July, a business providing designated services was expected to have an AML/CTF program and an AML/CTF compliance officer in place, to be training staff, and to be ready to report suspicious matters to AUSTRAC. Customer due diligence, including identifying clients and, where relevant, the people who ultimately own or control them, must generally be done before the service is provided.

Most tranche 2 businesses do not need to register as well as enrol. Registration is reserved for higher-risk services such as remittance and virtual asset services.

The rationale

The government’s case rests on the scale of the problem. Home Affairs Minister Tony Burke said when the laws commenced that more than $60 billion in illicit profits is laundered through the Australian economy each year. AUSTRAC says it regularly sees criminals using real estate and complex company and trust structures to hide the origin of funds. Those are precisely the transactions in which lawyers, accountants and agents act as gatekeepers.

What it means for deals and clients

The practical effect is already visible across Australian business. Clients buying property, restructuring a group, raising capital or setting up a family trust should expect more questions from their advisers: proof of identity, details of beneficial owners, and sometimes the source of funds or wealth. Advisers who cannot complete due diligence may be unable to act.

For brokers and corporate advisers, timetables should allow for this. A business sale or property settlement can stall if one party’s lawyer or agent cannot finish their checks. Businesses with layered structures, including offshore entities or nominee arrangements, should have ownership charts and supporting documents ready.

What to do now

  • If you provide any designated service: confirm you are enrolled. AUSTRAC has said that enrolment “is not optional” and that the alternative is enforcement.
  • If you are unsure whether you are caught: AUSTRAC is still working with industry to clarify the scope of designated services. Document your analysis and seek advice. Grey areas are not a defence.
  • If you are a client: treat requests for identification and ownership information as a routine part of doing business. Every regulated adviser now has to ask.

This article is general information only and is not legal advice. Readers should seek advice specific to their circumstances.