What business owners, trusts, companies and SMSF clients should know about the AML/CTF Tranche 2 Changes effective from 1 July 2026
From 1 July 2026, Australia’s anti-money laundering and counter-terrorism financing laws are being expanded to cover certain services provided by professional service firms, including accountants and trust and company service providers. These changes are commonly referred to as the AML/CTF Tranche 2 reforms.
For many clients, the most noticeable change will be that accountants may need to ask for more information about identity, ownership, control, source of funds and the nature of a transaction before providing certain services. This is not simply an administrative change – it is part of a broader national framework designed to reduce the risk of criminals misusing professional services.
Article at a glance
• AML/CTF obligations will apply from 1 July 2026 to certain designated services provided by tranche 2 entities, including professional services such as accountants.
• Newly regulated businesses that provide designated services will generally need to enrol with AUSTRAC and comply with customer due diligence, reporting, record keeping and AML/CTF program obligations.
• Clients may need to provide additional information before certain company, trust, business sale/purchase, ownership change or transaction-related work can commence.
• The rules are service-based, so not every accounting or tax task will be affected in the same way.
Why are the rules changing?
The reforms are intended to make it harder for criminals to use legitimate businesses, advisers and professional structures to disguise the movement or ownership of money. Professional advisers can be exposed to these risks where they assist with business structures, trusts, companies, acquisitions, ownership changes, asset transactions or other arrangements involving significant funds.
Australia’s AML/CTF regime is administered by AUSTRAC. AUSTRAC has released guidance and factsheets to help tranche 2 entities prepare for the new obligations and understand the services that may bring them within the regime.
What changes from 1 July 2026?
From 1 July 2026, certain services typically provided by accountants and trust and company service providers will become regulated as designated services. Where those services are provided and have the required link to Australia, the provider may need to comply with AML/CTF obligations.
For clients, this means Keypoint may need to request and verify additional information before commencing certain types of work. The exact information required will depend on the client, the entity structure, the nature of the service and the level of AML/CTF risk.
Services that may require additional checks.
The requirements are service-specific. Depending on the circumstances, additional checks may be required for work involving:
- setting up or restructuring companies, trusts, partnerships or other entities;
- changes to directors, shareholders, trustees, appointors, beneficiaries, controllers or beneficial owners;
- business acquisitions, disposals, due diligence or transaction support;
- trust and company service matters;
- transactions involving significant funds, complex ownership arrangements or overseas connections;
- source of funds or source of wealth enquiries for higher-risk matters.
Routine compliance work may not be affected in the same way as transaction, structuring or entity-control services. However, if AML/CTF checks are required for a particular matter, they must be completed before the relevant designated service is provided.
What information might clients need to provide?
Clients may be asked to provide documents and information such as:
- current identification documents for individuals;
- company extracts and details of directors, shareholders and beneficial owners;
- trust deeds and details of trustees, appointors, beneficiaries and controllers;
- SMSF trustee and member details where relevant;
- information about the purpose and nature of a transaction or engagement;
- source of funds or source of wealth information for certain transactions;
- details of overseas connections, high-risk jurisdictions or politically exposed persons where relevant.
These requests are designed to help identify who we are dealing with, who ultimately owns or controls an entity, and whether the service presents any increased money laundering, terrorism financing or proliferation financing risk.
What does this mean for Keypoint clients?
The practical impact is that some matters may require more upfront information and additional time before work can begin. This is particularly important for time-sensitive transactions, business purchases, business sales, company or trust changes, and SMSF-related structures.
To help avoid delays, clients should ensure their entity records are current and easy to access. This includes company registers, trust deeds, variation deeds, shareholder details, trustee details, identification documents and any documents showing ownership or control.
How clients can prepare now
- Check that identification documents are current and match your legal name.
- Keep company, trust and SMSF records up to date and accessible.
- Notify Keypoint of any changes to directors, shareholders, trustees, appointors, beneficiaries or controllers.
- Allow extra time for onboarding, structuring and transaction-related work from 1 July 2026.
- Be prepared to explain the commercial purpose of a transaction and the source of funds where requested.
Keypoint is here to help
Keypoint Accountants & Advisors will continue to support business owners, companies, trusts and SMSF clients through these changes. Our aim is to make the process as practical and clear as possible while meeting the new legal requirements.
Where additional information is needed, our team will let you know what is required and why. If you are planning a new structure, business acquisition, business sale, trust change, SMSF matter or ownership change after 1 July 2026, please contact us early so we can help you prepare.
Need assistance? Contact Keypoint Accountants & Advisors to discuss how the AML/CTF Tranche 2 changes may affect your business, trust, SMSF, company structure or upcoming transaction.
Disclaimer: This article provides general information only and should not be treated as legal advice. The application of AML/CTF obligations will depend on the specific services provided and the circumstances of each client.
