Tranche 2 AML/CTF Compliance for Lawyers: A Step-by-Step Timeline

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A small Australian law firm team reviewing their AML/CTF compliance checklist on a laptop in a casual open-plan office
⏱ 9 min read | Last update July 29, 2026 Solicitor Practice Manager

Australia's Tranche 2 AML/CTF reforms commenced on 1 July 2026. For legal practitioners providing designated services, the regime is now in effect and firms should also have lodged any changed AUSTRAC enrolment details by the 29 July 2026 deadline. This timeline covers every step your practice needed to take before go-live — and your ongoing obligations from here.

Australia's financial crime compliance landscape has undergone its most significant shift in a generation. From 1 July 2026, the Tranche 2 AML/CTF reforms have brought 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 needed in place before commencement, and the ongoing obligations you need to manage now that the reforms are live.

We have also created a Tranche 2 compliance checklist — a step-by-step breakdown of every obligation your firm needs to stay on top of now that the reforms are live. Download it now to track your ongoing compliance.

"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 Done
Apr–May 2026 Build and customise your AML/CTF program Done
May–Jun 2026 Implement, train all staff, set up CDD and record-keeping Done
1 Jul 2026 Full compliance required from day one Now live
29 Jul 2026 Update AUSTRAC enrolment details (if changed) Done
31 Mar 2027 First annual compliance report to AUSTRAC Ongoing

Full compliance timeline

Phase 1 — The groundwork (completed)
Dec 2024
Royal Assent — AML/CTF Amendment Act 2024 Law formally passed. Legal practitioners captured under the AML/CTF regime for the first time.
Aug 2025
AUSTRAC rules tabled in Parliament Detailed obligations and the risk-based approach confirmed.
Oct 2025
Core AUSTRAC guidance published Green light for firms to begin implementation planning.
Phase 2 — Pre-commencement steps (completed)
31 Mar 2026
Enrolled with AUSTRAC The portal opened on 31 March 2026. Enrolment was mandatory before providing any designated service.
Apr–May 2026
Built and customised your AML/CTF program
  • Appointed a compliance officer — formally designated, with delegated responsibility for compliance oversight.
  • Conducted and documented your ML/TF risk assessment — must be maintained and updated as your practice and risk environment change.
  • Created a written, risk-based AML/CTF program tailored to your practice's nature, size, complexity, services, and client base.
  • Obtained senior management sign-off — your program was approved before 1 July 2026.
May–Jun 2026
Implemented, trained, and set up systems
  • Trained every member of staff — all staff received AML/CTF training before 1 July 2026. Ongoing training is now required.
  • Integrated 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 — clear internal processes established for identifying and filing SMRs.
  • Established 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.
Phase 3 — Your ongoing obligations (now active)
1 Jul 2026
Compliance obligations are now active
  • 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 is now underway — all reporting entities must retain records for at least seven years.

Suspicious Matter Report (SMR) deadlines from 1 July 2026

24 hrs
Suspicions related to terrorism financing
3 days
Money laundering, tax evasion, proceeds of crime, or other offences
5 days
Where the SMR contains information protected by legal professional privilege
29 Jul 2026
AUSTRAC enrolment details updated Any changes to enrolment details must be lodged within 14 days of occurring via AUSTRAC Online. Firms should now have updated their enrolment record with AUSTRAC if any details changed since enrolling — and this remains a standing 14-day obligation every time enrolment details change going forward.
31 Mar 2027
First annual compliance report to AUSTRAC Submitted via the AUSTRAC Online portal. Covers your AML/CTF program, risk assessments, customer identification processes, and board/senior management oversight for the previous calendar year.

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

AUSTRAC Legal Profession Program Starter Kit

Sector-specific guidance and customisable program documents

AUSTRAC AML/CTF Reform Hub

All reform guidance, sector updates, and transitional rules

Law Council of Australia

National guidance and advocacy on Tranche 2 reforms

LawCPD — Tranche 2 Readiness Course

Practical online AML/CTF training for legal practitioners

Now that Tranche 2 reforms are live, staying compliant is an ongoing responsibility. Download our free checklist for a clear, practical breakdown of your firm's obligations from 1 July 2026 onwards.

Disclaimer: This LawCPD blog article is provided for general guidance only and does not constitute legal, financial, or other professional advice. It should not be relied upon as a substitute for advice tailored to your specific circumstances. While care has been taken in preparing this material, no warranty is given as to its accuracy, reliability, currency, or completeness. Laws, regulations, and guidance may change. To the maximum extent permitted by law, LawCPD disclaims all liability for any loss, damage, or expense arising from reliance on this material. This blog does not create a professional or advisory relationship between LawCPD and any user.
⏱ 9 min read | Last update July 1, 2026 Solicitor Practice Manager

Australia's Tranche 2 AML/CTF reforms commenced on 1 July 2026. For legal practitioners providing designated services, the regime is now in effect. This timeline covers every step your practice needed to take before go-live — and your ongoing obligations from here.

Australia's financial crime compliance landscape has undergone its most significant shift in a generation. From 1 July 2026, the Tranche 2 AML/CTF reforms have brought 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 needed in place before commencement, and the ongoing obligations you need to manage now that the reforms are live.

We have also created a Tranche 2 compliance checklist — a step-by-step breakdown of every obligation your firm needs to stay on top of now that the reforms are live. Download it now to track your ongoing compliance.

"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 Done
Apr–May 2026 Build and customise your AML/CTF program Done
May–Jun 2026 Implement, train all staff, set up CDD and record-keeping Done
1 Jul 2026 Full compliance required from day one Now live
29 Jul 2026 Update AUSTRAC enrolment details (if changed) Urgent
31 Mar 2027 First annual compliance report to AUSTRAC Ongoing

Full compliance timeline

Phase 1 — The groundwork (completed)
Dec 2024
Royal Assent — AML/CTF Amendment Act 2024 Law formally passed. Legal practitioners captured under the AML/CTF regime for the first time.
Aug 2025
AUSTRAC rules tabled in Parliament Detailed obligations and the risk-based approach confirmed.
Oct 2025
Core AUSTRAC guidance published Green light for firms to begin implementation planning.
Phase 2 — Pre-commencement steps (completed)
31 Mar 2026
Enrolled with AUSTRAC The portal opened on 31 March 2026. Enrolment was mandatory before providing any designated service.
Apr–May 2026
Built and customised your AML/CTF program
  • Appointed a compliance officer — formally designated, with delegated responsibility for compliance oversight.
  • Conducted and documented your ML/TF risk assessment — must be maintained and updated as your practice and risk environment change.
  • Created a written, risk-based AML/CTF program tailored to your practice's nature, size, complexity, services, and client base.
  • Obtained senior management sign-off — your program was approved before 1 July 2026.
May–Jun 2026
Implemented, trained, and set up systems
  • Trained every member of staff — all staff received AML/CTF training before 1 July 2026. Ongoing training is now required.
  • Integrated 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 — clear internal processes established for identifying and filing SMRs.
  • Established 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.
Phase 3 — Your ongoing obligations (now active)
1 Jul 2026
Compliance obligations are now active
  • 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 is now underway — all reporting entities must retain records for at least seven years.

Suspicious Matter Report (SMR) deadlines from 1 July 2026

24 hrs
Suspicions related to terrorism financing
3 days
Money laundering, tax evasion, proceeds of crime, or other offences
5 days
Where the SMR contains information protected by legal professional privilege
29 Jul 2026
Update AUSTRAC enrolment details Any changes to enrolment details must be lodged within 14 days of occurring via AUSTRAC Online. This deadline is 28 days away — act promptly if your details have changed.
31 Mar 2027
First annual compliance report to AUSTRAC Submitted via the AUSTRAC Online portal. Covers your AML/CTF program, risk assessments, customer identification processes, and board/senior management oversight for the previous calendar year.

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

AUSTRAC Legal Profession Program Starter Kit

Sector-specific guidance and customisable program documents

AUSTRAC AML/CTF Reform Hub

All reform guidance, sector updates, and transitional rules

Law Council of Australia

National guidance and advocacy on Tranche 2 reforms

LawCPD — Tranche 2 Readiness Course

Practical online AML/CTF training for legal practitioners

Now that Tranche 2 reforms are live, staying compliant is an ongoing responsibility. Download our free checklist for a clear, practical breakdown of your firm's obligations from 1 July 2026 onwards.

Disclaimer: This LawCPD blog article is provided for general guidance only and does not constitute legal, financial, or other professional advice. It should not be relied upon as a substitute for advice tailored to your specific circumstances. While care has been taken in preparing this material, no warranty is given as to its accuracy, reliability, currency, or completeness. Laws, regulations, and guidance may change. To the maximum extent permitted by law, LawCPD disclaims all liability for any loss, damage, or expense arising from reliance on this material. This blog does not create a professional or advisory relationship between LawCPD and any user.

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