Tranche 2 AML/CTF Compliance for Lawyers: A Step-by-Step Timeline
Posted on May 26, 2026
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
- 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.
- 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.
- 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
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
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.
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
- 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.
- 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.
- 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
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
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.
