Tranche 2 AML/CTF Compliance for Lawyers: A Step-by-Step Timeline
Posted on May 26, 2026
Australia's Tranche 2 AML/CTF reforms commence on 1 July 2026. For legal practitioners providing designated services, that deadline is weeks away. This timeline covers every step your practice needs to take — before and after go-live.
Australia's financial crime compliance landscape is undergoing its most significant shift in a generation. From 1 July 2026, the Tranche 2 AML/CTF reforms will bring legal practitioners providing designated services into a new, structured compliance regime for the first time.
This timeline breaks down the rollout in plain terms: what has already happened, what your practice needs in place before commencement, and the ongoing obligations you will need to manage once the reforms go live.
We have also created a Tranche 2 readiness checklist — a step-by-step breakdown of every action required before 1 July 2026. Download it now and use it alongside this timeline to track your progress.
"With the 1 July 2026 commencement date approaching, legal practices should already be thinking carefully about how the Tranche 2 reforms will operate in practice within their firm. For many firms, this will involve not only implementing an AML/CTF framework, but also reviewing onboarding processes, client due diligence procedures and internal training."
— Karen Lee, Principal, Legal Know-How · Author of Tranche 2 Readiness: AML/CTF Compliance for Legal Practitioners
Key dates at a glance
| Date | Milestone | Status |
|---|---|---|
| Dec 2024 | Royal Assent — AML/CTF Amendment Act 2024 | Done |
| Aug 2025 | AUSTRAC rules tabled in Parliament | Done |
| Oct 2025 | Core AUSTRAC guidance published | Done |
| 31 Mar 2026 | Enrol with AUSTRAC — portal open | Act now |
| Apr–May 2026 | Build and customise your AML/CTF program | Urgent |
| May–Jun 2026 | Implement, train all staff, set up CDD and record-keeping | Urgent |
| 1 Jul 2026 | Full compliance required from day one | Go-live |
| 29 Jul 2026 | Update AUSTRAC enrolment details (if changed) | Ongoing |
| 31 Mar 2027 | First annual compliance report to AUSTRAC | Ongoing |
Full compliance timeline
- Appoint a compliance officer — formally designated, with delegated responsibility for compliance oversight.
- Conduct and document your ML/TF risk assessment — must be maintained and updated as your practice and risk environment change.
- Create a written, risk-based AML/CTF program tailored to your practice's nature, size, complexity, services, and client base.
- Obtain senior management sign-off — your program must be approved before 1 July 2026.
- Train every member of staff — all staff must receive AML/CTF training before 1 July 2026 and on an ongoing basis thereafter.
- Integrate Customer Due Diligence (CDD) into client onboarding — not just at initial onboarding; review and update client information for ongoing relationships.
- Set up Suspicious Matter Report (SMR) pathways — establish clear internal processes for identifying and filing SMRs.
- Establish a 7-year record-keeping system — covering CDD activities, SMRs filed, transaction records, risk assessments, and training records. Systems must be capable of producing this data for AUSTRAC on request.
- Conduct initial CDD on every new client before providing services.
- Tipping-off prohibition is live — it is a criminal offence to disclose that an SMR has been submitted.
- 7-year record-keeping commences — all reporting entities must retain records for at least seven years.
Suspicious Matter Report (SMR) deadlines from 1 July 2026
Expert insight: what Tranche 2 readiness really means
To put the 1 July 2026 commencement into context for legal practices, we spoke with Karen Lee, Principal of Legal Know-How and author of the LawCPD interactive course Tranche 2 Readiness: AML/CTF Compliance for Legal Practitioners.
"The Tranche 2 reforms are ultimately about protecting the integrity of professional services and adopting a more structured, risk-based approach to managing financial crime risk. For legal practices, the focus should not just be on having policies in place, but on ensuring those policies are practical, understood by staff and capable of being applied consistently."
— Karen Lee, Principal, Legal Know-How · Author of Tranche 2 Readiness: AML/CTF Compliance for Legal Practitioners
Resources and where to get help
Sector-specific guidance and customisable program documents
All reform guidance, sector updates, and transitional rules
National guidance and advocacy on Tranche 2 reforms
Practical online AML/CTF training for legal practitioners
State and territory law society resources: NSW · VIC · QLD · WA · SA · ACT · NT · TAS
Want to stay ahead of Tranche 2 reforms? Download our free checklist for a clear, practical breakdown of every step your firm needs to take before 1 July 2026.
Australia's Tranche 2 AML/CTF reforms commence on 1 July 2026. For legal practitioners providing designated services, that deadline is weeks away. This timeline covers every step your practice needs to take — before and after go-live.
Australia's financial crime compliance landscape is undergoing its most significant shift in a generation. From 1 July 2026, the Tranche 2 AML/CTF reforms will bring legal practitioners providing designated services into a new, structured compliance regime for the first time.
This timeline breaks down the rollout in plain terms: what has already happened, what your practice needs in place before commencement, and the ongoing obligations you will need to manage once the reforms go live.
We have also created a Tranche 2 readiness checklist — a step-by-step breakdown of every action required before 1 July 2026. Download it now and use it alongside this timeline to track your progress.
Download the free checklist"With the 1 July 2026 commencement date approaching, legal practices should already be thinking carefully about how the Tranche 2 reforms will operate in practice within their firm. For many firms, this will involve not only implementing an AML/CTF framework, but also reviewing onboarding processes, client due diligence procedures and internal training."
— Karen Lee, Principal, Legal Know-How · Author of Tranche 2 Readiness: AML/CTF Compliance for Legal Practitioners
Key dates at a glance
| Date | Milestone | Status |
|---|---|---|
| Dec 2024 | Royal Assent — AML/CTF Amendment Act 2024 | Done |
| Aug 2025 | AUSTRAC rules tabled in Parliament | Done |
| Oct 2025 | Core AUSTRAC guidance published | Done |
| 31 Mar 2026 | Enrol with AUSTRAC — portal open | Act now |
| Apr–May 2026 | Build and customise your AML/CTF program | Urgent |
| May–Jun 2026 | Implement, train all staff, set up CDD and record-keeping | Urgent |
| 1 Jul 2026 | Full compliance required from day one | Go-live |
| 29 Jul 2026 | Update AUSTRAC enrolment details (if changed) | Ongoing |
| 31 Mar 2027 | First annual compliance report to AUSTRAC | Ongoing |
Full compliance timeline
- Appoint a compliance officer — formally designated, with delegated responsibility for compliance oversight.
- Conduct and document your ML/TF risk assessment — must be maintained and updated as your practice and risk environment change.
- Create a written, risk-based AML/CTF program tailored to your practice's nature, size, complexity, services, and client base.
- Obtain senior management sign-off — your program must be approved before 1 July 2026.
- Train every member of staff — all staff must receive AML/CTF training before 1 July 2026 and on an ongoing basis thereafter.
- Integrate Customer Due Diligence (CDD) into client onboarding — not just at initial onboarding; review and update client information for ongoing relationships.
- Set up Suspicious Matter Report (SMR) pathways — establish clear internal processes for identifying and filing SMRs.
- Establish a 7-year record-keeping system — covering CDD activities, SMRs filed, transaction records, risk assessments, and training records. Systems must be capable of producing this data for AUSTRAC on request.
- Conduct initial CDD on every new client before providing services.
- Tipping-off prohibition is live — it is a criminal offence to disclose that an SMR has been submitted.
- 7-year record-keeping commences — all reporting entities must retain records for at least seven years.
Suspicious Matter Report (SMR) deadlines from 1 July 2026
Expert insight: what Tranche 2 readiness really means
To put the 1 July 2026 commencement into context for legal practices, we spoke with Karen Lee, Principal of Legal Know-How and author of the LawCPD interactive course Tranche 2 Readiness: AML/CTF Compliance for Legal Practitioners.
"The Tranche 2 reforms are ultimately about protecting the integrity of professional services and adopting a more structured, risk-based approach to managing financial crime risk. For legal practices, the focus should not just be on having policies in place, but on ensuring those policies are practical, understood by staff and capable of being applied consistently."
— Karen Lee, Principal, Legal Know-How · Author of Tranche 2 Readiness: AML/CTF Compliance for Legal Practitioners
Resources and where to get help
Sector-specific guidance and customisable program documents
All reform guidance, sector updates, and transitional rules
National guidance and advocacy on Tranche 2 reforms
Practical online AML/CTF training for legal practitioners
State and territory law society resources: NSW · VIC · QLD · WA · SA · ACT · NT · TAS
Want to stay ahead of Tranche 2 reforms? Download our free checklist for a clear, practical breakdown of every step your firm needs to take before 1 July 2026.
Download the free checklist
