Newly regulated services

Tranche 2 client onboarding workflows

“Tranche 2” is commonly used for the expansion of Australia’s AML/CTF regime to certain professional, property and other high-risk services. It is a market label, not a substitute for checking the designated services.

Last reviewed: · Editorial owner: Onboard Australia

General editorial information. Onboard is a domain portfolio and does not provide AML/CTF software or advice.

01

The 1 July 2026 context

AUSTRAC states that businesses providing certain newly regulated designated services are regulated from 1 July 2026. The relevant groups include real-estate professionals, lawyers, conveyancers, accountants and trust and company service providers, but only in relation to services within the law’s scope.

Regulatory note: A business should first determine whether it provides a designated service, then establish the obligations applying to its activities.

02

Onboarding may become a controlled process

Where obligations apply, a client-opening process may need to establish the customer and relevant persons, understand the requested service, assess risk, apply the appropriate due-diligence path and retain decision evidence.

03

Higher-risk and existing relationships

Enhanced and ongoing due diligence are not simply extra form fields. They can require targeted controls, review and updated information according to the customer’s risk and the reporting entity’s policies. Transitional and existing-customer questions should be checked against current AUSTRAC material.

04

Governance before tooling

Technology decisions should follow clear ownership, escalation paths, policies and an understanding of the data the organisation needs to handle. A vendor cannot determine legal scope for a business merely from its profession.

Illustrative workflow

A controlled path, not a compliance template.

Illustrative workflow only — not a compliance template. The required process depends on the reporting entity, designated service, customer and risk.

01

Check the service

Map actual activities against current designated-service guidance.

02

Understand the customer

Identify the customer, representatives and relevant entity relationships.

03

Assess risk

Apply the reporting entity’s documented customer-risk approach.

04

Select the review path

Use the initial, enhanced or other pathway that applies to the circumstances.

05

Keep evidence current

Record decisions and support later review as required.

Primary sources

Regulatory statements are linked to current AUSTRAC guidance. Provider facts on the market page link to each provider’s official website.