Who Tranche 2 will apply to
The reforms are expected to apply to the following professions, but only when they perform a designated service:
- Accountants and bookkeepers
- Lawyers and legal service providers
- Conveyancers and settlement agents
- Real estate agents and property managers
- Trust and company service providers
It is a common misconception that all accountants, bookkeepers, lawyers, and real estate professionals will be captured by Tranche 2. In reality, only businesses that perform specific designated services—defined under the AML/CTF Act and expanded through Tranche 2—become reporting entities.
What are designated services?
A designated service is a type of activity that carries elevated money laundering or terrorism financing risk. When a business conducts one of these activities, the AML/CTF Act applies, and the business becomes a reporting entity with compliance obligations.
Examples of designated services (as proposed under Tranche 2) include:
For accountants and bookkeepers
A practice will be captured when it performs services such as:
- Managing client funds held in trust or controlling client money
- Providing advice or assistance for setting up companies, trusts, or other legal arrangements
- Preparing, arranging, or executing transactions on behalf of a client (e.g., purchase/sale of property or assets)
- Arranging for another person to receive, move, or store funds
General bookkeeping, BAS preparation, tax returns, and routine accounting work do not automatically trigger AML/CTF obligations unless they involve a designated service.
For lawyers and conveyancers
A legal practice becomes a reporting entity when it:
- Manages client funds or trust accounts
- Facilitates real estate transactions
- Assists with company or trust formation
- Prepares or carries out complex financial transactions on behalf of clients
For real estate professionals
A real estate agency is captured when it participates in:
- The purchase or sale of residential or commercial property
- Leasing of high-value commercial property
- Movement or holding of client funds relating to a property transaction
Routine property management may not trigger Tranche 2 obligations unless client money flows are involved.
For trust and company service providers
A business becomes subject to AML/CTF obligations when it:
- Forms companies, partnerships, or trusts
- Acts as a nominee director or trustee
- Provides a registered office, business address, or administrative services for clients
What Tranche 2 obligations include
Tranche 2 entities performing designated services will need to implement:
- Customer Due Diligence (CDD)
- Enhanced Due Diligence (EDD) for high-risk clients
- Ongoing monitoring
- Risk-based AML/CTF programs
- Suspicious matter reporting (SMRs)
- Record-keeping for at least seven years
These obligations are similar to those already required of banks, lenders, and remitters.
How Annature helps businesses prepare for Tranche 2
Annature provides the key verification and compliance components needed to meet expected Tranche 2 obligations, including:
- Electronic KYC verification with biometric matching
- Real-time AML and CTF screening via ComplyCube and RealAML
- Identification of PEPs, sanctions, and adverse media
- Comprehensive event logs and audit-ready evidence
- Secure, ISO-certified information handling
- Seamless integration into onboarding and signing workflows
For accountants, lawyers, real estate professionals, and other DNFBPs, Annature offers a scalable, low-friction way to embed compliance into everyday client onboarding—long before Tranche 2 becomes mandatory.