Tranche 2 Is Still Coming: What the latest delay rumours really mean

Author, Amy Bell, CEO

There’s been a lot of chatter across the AML community lately about potential delays to Australia’s AML/CTF reforms. Some commentary has gone further, suggesting enforcement for certain sectors could drift as far out as 2029. It’s understandable that this has caused some confusion, particularly for law firms, accountants, conveyancers and real estate professionals who are trying to work out when they really need to act. 

So let’s strip this back and deal with the facts, not fear. 

First, a quick refresher: Tranche 1 vs Tranche 2 

Australia’s AML/CTF reforms are being implemented in stages.  Tranche 1 entities include banks, financial services providers, casinos and gambling businesses. These entities have been regulated for many years but their regimes are now being significantly updated. The bar has been raised substantially, requiring new systems, new processes and deep technical change. 

Tranche 2 entities include lawyers, accountants, real estate agents, conveyancers and trust and company service providers. These professions have historically sat outside the AML regime, which is precisely the gap the reforms are designed to close. 

Where the delay rumours are actually coming from 

The speculation around delays is largely tied to Tranche 1, not Tranche 2. Financial institutions are currently dealing with: - overlapping regulatory reforms, legacy systems that are difficult to adapt, limited AML talent across the market and genuine capacity constraints. 

There is discussion about whether elements of Tranche 1 implementation or supervision need to be extended to allow institutions to bed down changes properly. That is a very different conversation from abandoning or pausing Tranche 2. 

The key point to takeaway 

There is no signal that Tranche 2 is being scrapped, abandoned or indefinitely delayed. 

Australia remains under sustained international pressure to regulate professional services. Leaving Tranche 2 unresolved would expose Australia to reputational and regulatory consequences that simply aren’t palatable. 

For those wanting a deeper, practical understanding of why these reforms matter, our upcoming masterclasses explore real enforcement case studies and translates them into clear, actionable guidance for firms. You can book a place here.

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