E01 2026/27 Australia's Anti-Money Laundering Laws Just Changed. Here's What You Need to Know.
On the first of July 2026, something significant happened in the Australian legal landscape — and most people outside the profession missed it entirely.
Australia's anti-money laundering laws expanded. Significantly. For the first time in nearly twenty years, lawyers, conveyancers, accountants, and real estate agents became regulated under the same financial crime framework as banks.
If you buy property, run a business through a company or trust, manage an estate, or use a legal or financial professional for any significant transaction — this change affects you.
Here is what you need to know.
Australia has had anti-money laundering laws since 2006 under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth). But for almost two decades, those laws only applied to what regulators call Tranche 1 entities — banks, financial institutions, casinos, and remittance services.
Lawyers, accountants, conveyancers, and real estate agents — the professionals who facilitate the vast majority of significant financial transactions in this country — sat entirely outside that regime.
This left a gap that the global financial crime watchdog, the Financial Action Task Force (FATF), had been criticising Australia over for years. Property is one of the most commonly used vehicles for money laundering. When the professionals involved in those transactions are not required to ask any questions, that door stays open.
The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 closed that door. It received Royal Assent on 10 December 2024, and the obligations for newly regulated professions — known as Tranche 2 entities — commenced on 1 July 2026.
The Tranche 2 reforms capture:
Approximately 80,000 new businesses have joined the regulatory regime — one of the largest expansions of Australia's financial crime framework since it began.
The obligation does not attach to every professional for every piece of work. It attaches to the provision of what the legislation calls a designated service — broadly, any professional service that involves money moving, property transferring, or entities being created or controlled.
For lawyers and conveyancers, designated services under Table 6 of the AML/CTF Act include:
Pure legal advice — sitting with a lawyer to understand your rights — is not itself a designated service. Litigation representation is not a designated service. But the moment work involves a transaction, a structure, or money or property moving, the obligations apply. Importantly, the obligations can arise before a transaction completes — including during preparatory steps.
For a practice like Ellison-Whyte Law, which handles conveyancing, private lending, estate administration, SMSF structuring, family law property settlements, and business law — virtually every service we provide is captured.
Every newly regulated firm must now meet eight core compliance obligations.
1. Enrol with AUSTRAC
All Tranche 2 entities must enrol with the Australian Transaction Reports and Analysis Centre (AUSTRAC). Enrolment opened on 31 March 2026
and must be completed by 29 July 2026.
2. Conduct a Risk Assessment
Firms must formally identify, assess, and understand the money laundering and terrorism financing risks specific to their practice —
considering client types, transaction types, delivery channels, and geographic connections.
3. Implement an AML/CTF Program
A written, documented compliance program setting out the firm's policies, procedures, and controls for managing identified risks. This
replaces the old prescriptive two-part model with a unified, outcomes-focused, risk-based approach.
4. Customer Due Diligence (CDD)
Before providing a designated service, firms must verify a client's identity. For individuals, this means government-issued photo ID. For
companies and trusts, it extends to identifying beneficial owners — the people who ultimately own or control the structure.
5. Sanctions and PEP Screening
Clients must be screened against sanctions lists and checked for politically exposed person (PEP) status — that is, whether they hold or
have held a prominent public function, or are a close associate or family member of someone who has.
6. Suspicious Matter Reporting
Where a firm forms a suspicion that a transaction involves proceeds of crime or is connected to terrorism financing, it must report that
suspicion to AUSTRAC. For lawyers, this intersects with legal professional privilege — an area the profession is actively working through.
7. Record Keeping
All client identification records, transaction records, and due diligence steps must be retained for seven years.
8. Staff Training
All staff involved in designated services must be trained on the firm's AML/CTF obligations.
If you are engaging a lawyer, conveyancer, accountant, or real estate agent for any significant transaction from 1 July 2026, you can expect the onboarding process to include additional steps.
This is not your professional being overly cautious. It is not a reflection on your integrity. It is a legal obligation — and one that ultimately protects the integrity of the property market and financial system that we all participate in.
The practical impact for most clients is modest. A small amount of additional documentation at the start of a matter. In exchange, the professionals handling your property and wealth transactions are now formally accountable for financial crime compliance to the same standard as the banking system.
We have not waited for the commencement date to act.
Ellison-Whyte Law has enrolled with AUSTRAC as a reporting entity. We have developed a comprehensive AML/CTF Compliance Program tailored to our practice areas. We have built client due diligence templates and an intake questionnaire that captures the information we are now required to collect. And as Principal, I serve as the firm's appointed AML/CTF Compliance Officer.
Our compliance infrastructure is in place. Our team is trained. And we are ready to continue serving clients across the Mornington Peninsula, South Gippsland, and Victoria-wide under the new framework.
If you have questions about how the new laws affect an upcoming matter — whether that is a property purchase, a private loan, an estate, or a business transaction — we welcome you to get in touch.
This week on The Unsolicitor's Opinion, I have dedicated a full episode to walking through the Tranche 2 reforms in plain English — what changed, why it matters, and what it means for you.
You can find the episode on Spotify and YouTube now.
If you have a property transaction, estate matter, business structure, or private lending arrangement you need legal assistance with, our team is here to help.
This article is general information only and does not constitute legal advice. For advice specific to your circumstances, please contact Ellison-Whyte Law or another qualified legal practitioner.
Ellison-Whyte Law Pty Ltd — ABN 84 491 886 866 — Shop 2, 3056 Frankston-Flinders Road, Balnarring VIC 3926