AML/CTF reforms: what the 2026 changes mean for accountants, lawyers, real estate agents and their clients

For years, Australia's anti-money laundering and counter-terrorism financing (AML/CTF) laws applied mainly to banks, remittance services, casinos and similar businesses. Accountants, lawyers, conveyancers and real estate agents were largely outside the regime, even though their services can be used to buy property, set up companies and trusts, or move money. That has now changed. From 1 July 2026, many of these professionals are regulated, and their clients will notice the difference.

This article explains the reforms in general terms, for both the firms affected and the people and businesses who use them.

What changed

The AML/CTF Amendment Act 2024 extends Australia's AML/CTF regime to a group of professions often called "tranche 2". They include:

• accountants;
• lawyers;
• conveyancers;
• real estate agents;
• trust and company service providers;
• dealers in precious stones and precious metals.

Obligations for these newly regulated businesses start on 1 July 2026. Changes for businesses that were already reporting entities, such as banks and remitters, started earlier, on 31 March 2026.

As accountants, we are among the businesses the reforms bring in.

It depends on the service, not the job title

The obligations attach to particular "designated services", not to a profession as a whole. An accountant who only prepares tax returns may be in a different position from one who sets up companies and trusts for clients. In broad terms, the designated services for tranche 2 businesses include:

• buying or selling real estate, and assisting someone to do so;
• setting up companies, trusts and other legal arrangements, or transferring them;
• acting as, or arranging for someone to act as, a nominee, such as a nominee director or shareholder;
• receiving, holding and handling client money or property, for example through a trust account;
• certain dealings in precious stones and metals.

Each firm needs to work out which of its services are designated services. That analysis drives everything else.

What regulated businesses must do

A business that provides designated services generally has five core obligations.

1. Enrol with AUSTRAC

AUSTRAC is Australia's AML/CTF regulator and financial intelligence agency. Businesses providing designated services must enrol with it.

2. Have an AML/CTF program

The program is the business's documented approach to identifying, managing and reducing the risk that its services are used for money laundering or terrorism financing. It should reflect the firm's actual services, clients and risks, be approved by senior management, and include staff training, oversight by a compliance officer and regular independent review.

3. Carry out customer due diligence

Before providing a designated service, the business must identify its customer and verify that identity. For companies, trusts and other entities, that includes identifying the beneficial owners, the individuals who ultimately own or control the entity, and understanding how it is structured. Due diligence continues during the relationship, with more checks for higher-risk customers, such as politically exposed persons or customers connected to higher-risk countries.

4. Report to AUSTRAC

Regulated businesses must report suspicious matters to AUSTRAC. Depending on the service, other reports may also apply, such as reports of certain cash transactions of $10,000 or more. It is an offence to tip off a customer that a suspicious matter report has been made or is being considered.

5. Keep records

Businesses must keep records of customer due diligence, transactions and their AML/CTF program for the required periods, so they can show AUSTRAC what they did and why.

What clients should expect

If you use an accountant, lawyer, conveyancer or real estate agent for a designated service, expect the process to feel more like opening a bank account than it did before.

• Being asked for identification. You may be asked for photo ID, such as a passport or driver's licence, and to verify it electronically or in person. This can apply even if you have been a client for years.
• Details of beneficial owners. If you act through a company or trust, expect to be asked who owns and controls it. For a company, that generally means anyone holding 25% or more, or otherwise in control. For a trust, it can include trustees, appointors, settlors and key beneficiaries. You may need to provide trust deeds, company extracts or other documents.
• Source of funds and wealth. Particularly for property purchases and larger transactions, you may be asked where the money is coming from: savings, a loan, the sale of another asset, an inheritance or business income. In higher-risk situations, you may be asked about your wealth more generally.
• The purpose of the service. Firms need to understand what you are trying to achieve, so they can assess whether the activity makes sense.
• Ongoing updates. You may be asked to update your details from time to time, especially if your circumstances or structure change.

If a firm cannot complete its due diligence, it may be unable to act for you. That is a legal requirement, not a judgement about you.

Being asked for ID and the source of your funds is now a normal part of buying property or setting up a company. Having the documents ready saves time for everyone.

Practical tips for clients

• Keep current photo ID on hand.
• For companies and trusts, keep the constitution, trust deed, share register and details of directors and trustees in one place.
• Before a property purchase, have evidence ready of where the deposit and funds are coming from, such as bank statements or loan approvals.
• Expect the same questions from more than one adviser on the same transaction. Each firm has its own obligation.

For firms getting ready

For firms newly brought in, the work involves deciding which services are designated, assessing risk, writing and approving a program, training staff, setting up identification and verification processes, and building record-keeping and reporting into daily work. AUSTRAC publishes guidance for each of the new sectors, and professional bodies have produced their own materials. Firms should take advice on their specific obligations.

Kainos's directors also built CompliDesk, AML/CTF compliance software for Australian firms.

How we can help

If you are a client of ours, we will explain what we need from you and why when it applies. If you are setting up or restructuring a company or trust and want to understand what information you will be asked for, contact us or read about our business structuring services.

This article is general information only and does not take into account your circumstances. It is not financial product advice. Speak to a qualified, licensed adviser before acting on it.