Your Tranche 2 Preparation Timeline: What to Do When
With Australia’s Tranche 2 AML obligations kicking in on 1 July 2026, the countdown has begun. Whether you’re a lawyer, accountant, real estate agent, or jeweller, getting compliance-ready takes time—and the clock is ticking. This post outlines a month-by-month preparation timeline covering risk assessments, AML/CTF Program development, staff training, technology setup, and enrolment. If you’re unsure when to act or what to prioritise, this guide breaks it down so you can move with confidence. Start early, stay structured, and be ready before the deadline.
With Tranche 2 AML compliance obligations commencing on 1 July 2026, Australian real estate professionals, lawyers, accountants, and jewellers have less than 12 months to implement comprehensive compliance frameworks. This detailed timeline outlines what your business needs to do - and when - to be fully prepared for Australia’s most significant regulatory expansion in decades.
Key Dates to Note
- August 2025: AUSTRAC finalises AML/CTF Rules
- October 2025: Core guidance released
- December 2025: Sector-specific guidance available
- 31 March 2026: Virtual asset service provider changes commence
- 1 July 2026: Tranche 2 obligations commence
- 29 July 2026: Deadline for AUSTRAC enrolment (i.e., within 28 days of commencement)
Phase 1: Foundation (Q4 2025 - Q1 2026)
October - December 2025: Planning & Assessment
Weeks 1–2: Project Initiation
- Form a compliance project team
- Allocate budget
- Create a project plan with milestones
- Engage external advisors if required (👋🏻 Hello!)
Weeks 3–4: Service Assessment
- Review all services against designated service definitions
- Identify which services trigger AML obligations
- Assess customer types and transaction volumes
- Map client onboarding processes
Month 2: Risk Assessment
- Conduct a full ML/TF risk assessment
- Identify high-risk clients and transactions
- Document geographic risks and controls
- Establish risk appetite statements
Month 3: Framework Design
- Draft AML/CTF Program
- Define customer due diligence (CDD) procedures
- Design transaction monitoring and record-keeping protocols
- Establish reporting obligations framework
January - March 2026: Policy Development
January 2026
- Finalise AML/CTF Program based on AUSTRAC guidance
- Develop identification and sanctions screening procedures
- Define enhanced due diligence (EDD) workflows
- Identify suspicious activity indicators
February 2026
- Develop staff training content
- Implement compliance monitoring processes
- Establish record retention and incident management procedures
- Plan for independent program review
March 2026
- Submit AML Program for senior management approval
- Conduct legal review of policies (especially for law firms)
- Integrate compliance tools with existing systems
- Begin staff awareness training
- Select technology vendors if needed
Phase 2: Implementation (Q1 - Q2 2026)
April 2026: Systems & Training
Weeks 1–2: System Setup
- Deploy client ID verification (IDV) system
- Implement sanctions and PEP screening (external vendor/tech)
- Launch transaction monitoring based on your transaction monitoring program (TMP)
- Establish digital record-keeping
- Test system integration
Weeks 3–4: Training
- Deliver AML training to all staff
- Appoint and train an AML Compliance Officer (MUST do this)
- Train frontline staff on CDD and risk indicators
- Launch ongoing training schedule
May 2026: Testing & Optimisation
Weeks 1–2: Process Testing
- Test onboarding, monitoring, and reporting
- Simulate suspicious activity reporting
- Validate record-keeping and system effectiveness
Weeks 3–4: Optimisation
- Adjust procedures and training materials
- Resolve gaps identified in testing
- Prepare communication materials for clients
Phase 3: Readiness (Q2 - Q3 2026)
June 2026: Final Checks
Weeks 1–2: Internal Review
- Validate policies, procedures, and staff competency
- Complete final system checks
- Review privilege protections (for legal firms)
Weeks 3–4: Go-Live Readiness
- Finalise client communications
- Prepare AUSTRAC enrolment (see AUSTRAC website)
- Set up monitoring dashboards
- Schedule post-implementation review
You can subscribe for updates on AML/CTF reform to receive more information about when you can enrol and register.
Critical Success Factors
Early Planning
Starting in Q4 2025 allows for methodical, pressure-free preparation.
Leadership Buy-In
Senior management support is critical for resourcing and accountability.
Staff Training
Effective compliance depends on well-trained, informed staff across all levels.