The AML regime is coming – are we ready?

From 31 March 2026, that is changing and enrolment with AUSTRAC opens for newly regulated businesses. The obligations under Australia’s long-anticipated Tranche 2 AML/CTF reforms will commence from 1 July 2026, with accountants, lawyers, real estate agents and other professional services formally bought within the regime. Newly regulated entities will then need to be enrolled by 29 July 2026. For many accounting firms, this will be the first time they sit directly inside the anti-money laundering regulatory regime.

Across the profession, the reaction is ranging from curiosity, to confusion, to a quiet sense of panic. So, what do these reforms mean in practice?

If you think about it from a criminal’s perspective, accountants have always been part of the picture. Accountants help establish companies, structure investments, move funds across entities and jurisdictions, and advise on tax and asset structures. These services are completely legitimate, and they are also exactly the type of activities criminals can exploit to disguise illicit funds.

That is why internationally, for a long-time professional services firms have been captured under AML frameworks and Australia has simply been late to the party.

The Tranche 2 reforms are designed to close that gap by recognising that gatekeeper professions like accountants play a critical role in protecting the financial system from misuse. It is there to ensure firms understand their risk exposure and have sensible processes in place to detect and report suspicious activity.

The big shift for firms will be becoming a regulated reporting entity for the first time and with that there are several core obligations.

Firstly, firms will need to conduct an AML/CTF risk assessment to identify how their services could potentially be misused for money laundering or terrorism financing.

This involves implementing a formal AML/CTF program, including policies and procedures covering customer identification, risk management, and monitoring.

Team members will need training, so they understand how to recognise suspicious activity and what to do if they encounter it.

And lastly, firms need to report certain matters to AUSTRAC, including suspicious transactions and threshold transactions where relevant.

At first glance this can sound intimidating, but these obligations are largely about building structured processes around activities that firms are already doing.

Most accountants already ask questions about clients, understand their businesses and keep records of transactions. AML simply formalises this into a consistent framework.

Where we are seeing the biggest stress for accountants is the uncertainty, not necessarily the work involved.

Firms are asking the same questions. Do these obligations apply to all my services, or only some? What does a risk assessment actually look like? How detailed do my policies need to be? How do I train team members without turning them into compliance specialists?

These are valid questions, particularly for smaller firms that have never operated under a financial crime regulatory regime before. They highlight an important point that compliance is about clarity not about necessarily about paperwork.

It is tempting to view AML purely as another regulatory burden, but once firms understand their risk profile and the expectations placed on them, the framework becomes much more manageable.

Strong AML frameworks help to understand their clients better, identify unusual transactions earlier and protect themselves from becoming unwitting participants in financial crime.

They also increasingly matter from a commercial perspective. Institutional partners like banks and financial services firms are already asking accounting firms to demonstrate their AML maturity. As expectations rise, having a credible compliance framework will become an important part of maintaining professional relationships.

In other words, AML is quickly moving from a regulatory obligation to a business credibility issue. With the March 2026 commencement date approaching, the key message for accounting firms is simple: start early.

The firms that approach AML proactively will find the transition far smoother than those scrambling to implement policies at the last minute.

The good news is that the industry is already responding with practical solutions. New frameworks combining technology, training and structured compliance tools are emerging to help professional services firms implement AML programs without overwhelming their teams. 

Ultimately, the goal of AML regulation is not to bury professionals in paperwork. It is to ensure the trusted advisers at the centre of Australia’s financial system, including accountants have the awareness, systems and support needed to prevent that system from being exploited.

The firms that will succeed under Tranche 2 won’t be the ones scrambling to comply at the last minute, but those who prepare early and approach AML with clarity and intent. For accountants, that means embedding practical, risk-based processes into the way they already work not overcomplicating it but taking it seriously. Preparedness won’t just make compliance easier, it will be what sets credible, trusted firms apart.

Steve Sloane, managing director, Link Wealth Accounting