As we enter 2026, Australia’s expanded AML/CTF regime is no longer theoretical. It is operational reality in the making.
With the July 2026 commencement deadline approaching fast, businesses captured under the Tranche 2 reforms now face the most significant compliance shift in a generation.
Following recent presentations at AML Edge 2025, Christopher Frankish has seen first-hand the questions organisations are asking and the gaps that still need to be closed.
The message is consistent. Waiting is no longer an option.
Read highlights from Christopher Frankish’s AML Edge 2025 sessions here.
What Tranche 2 Businesses Should Be Prioritising Now
For accountants, real estate professionals, lawyers and other newly regulated service providers, the coming months should focus on building foundations rather than scrambling at the last minute.
For a detailed breakdown of AML/CTF obligations and compliance support options, view our AML/CTF compliance services.
Christopher highlights four (4) immediate priorities.
1. Build Your Risk Assessment First
Your AML/CTF program starts with risk assessment.
Understanding who your clients are, what services you provide, how transactions flow and where geographic exposure exists allows businesses to design proportionate controls rather than generic compliance templates.
Risk assessments should be treated as living frameworks that evolve as your business grows.
2. Review Client Onboarding and Legacy Clients
One of the biggest operational changes under Tranche 2 will be onboarding.
New and existing clients will increasingly require consistent identification, verification and ongoing monitoring.
This will impact workflows, client communications and data management processes. All of this needs planning well before July 2026.
3. Select Technology That Matches Your Business Model
Technology is not one-size-fits-all.
Many firms will adopt AML systems for the first time. Selecting platforms that integrate with existing practice management tools is critical to avoiding unnecessary operational friction.
The right technology should support efficiency, not slow teams down.
4. Train Teams Early
Compliance frameworks fail when staff do not understand them.
Training should begin early so teams understand risk indicators, onboarding changes and escalation processes before regulatory obligations go live.
Why Early Preparation Creates Competitive Advantage
Strong AML compliance is not only about satisfying regulators.
Businesses that implement clear, efficient and low-friction processes build stronger client trust, reduce operational risk and demonstrate professionalism to counterparties and regulators alike.
Those who wait risk rushed implementation, poor client experiences and avoidable compliance errors.
Looking Ahead
With Tranche 2 reforms firmly on the national regulatory agenda, 2026 will be the year many professional services businesses redefine how compliance is embedded into daily operations.
As Christopher Frankish continues to advise organisations across Australia, the consistent advice remains simple.
Start early. Build properly. Stay adaptable.
Looking for more detailed guidance on AML/CTF program development, risk assessments and Tranche 2 readiness?
Explore our AML/CTF compliance services.
Speak With Christopher Frankish
If your business will be impacted by Tranche 2 AML/CTF reforms and you want practical guidance on risk assessment, AML program design or implementation strategy.
Want deeper insight from AML Edge 2025?
Explore Christopher Frankish’s AML Edge 2025 Highlights
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