INDUSTRIES IN FOCUS

Does Tranche 2  apply to your industry? 

INDUSTRIES IN FOCUS

Does Tranche 2 apply to your industry?

One of the most common misunderstandings about Tranche 2 is that it applies only to large firms or specialist operators. The law is triggered not by size, but by what you do.

The AML/CTF Act does not regulate professions in the abstract. It regulates designated services that create a high risk of money laundering or terrorism financing. If a firm provides even one designated service, it becomes a reporting entity for those activities and must comply with the AML/CTF regime in full.

This means thousands of professional practices will fall within scope, regardless of business size.

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If you provide a designated service, you are in scope

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Real Estate & Property

Facilitating property transfers or handling transaction funds.

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Legal & Conveyancing

Services involving client funds, asset transfers or legal structures.

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Accounting & Advisory

Structuring, entity management or authority over client funds.

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Tranche 2 also extends to trust and company service providers, precious metals and stone dealers, and certain other roles adjacent to property and financial structuring.

Size is no protection

A sole practitioner law firm holding $200,000 in trust funds carries the same AML risk as a national firm holding $200 million. A suburban real estate agency handling one high-value foreign purchase can face the same regulatory exposure as a major franchise network.

In fact, while corporate breaches get the headlines, regulatory experience suggests criminals often target smaller firms with less mature compliance environments as they can be easier to infiltrate.

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quote-iconCriminals are more sophisticated today in their use of technology and other crime enablers. They hide and access their illicit profits through money laundering and exploitation of digital currency systems, and increasingly operate remotely and online to obscure their identities and scale their enterprises.

We are also seeing more recruitment and use of professional facilitators such as lawyers, accountants and real estate agents.”

– Heather Cook, ACIC CEO and Director of the AIC*

How Tranche 2 works in practice

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Compliance done well protects your brand, reduces risk and builds trust.

Industry Quick Links

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You don’t have to figure this out alone

I'm here to help. Book a complimentary 15-minute AML risk profile assessment and I'll walk you through where your business stands today, what to prioritise and how to operationalise your obligations before 1 July 2026.

– Raji Lal, National Sales Executive

Call: 1300 512 387

* Australian Criminal Intelligence Commission, Serious and organised crime is affecting you – even if you don’t realise it, 2025