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title: Preparing For AUSTRAC Tranche 2 AML/CFT (Pre-March 31st) | Realaml Help Center
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# Preparing For AUSTRAC Tranche 2 AML/CFT (Pre-March 31st) | Realaml Help Center

### Preparing For AUSTRAC Tranche 2 AML/CFT (Pre-March 31st)

![](https://help.realaml.com/hubfs/Knowledge%20Base%20Import/JORDAN_HEADSHOT_2025-1741884224-Apr-29-2026-05-29-25-2283-AM.png)

 Written by Jordan

### Who is Realaml? Only 1 of 2 ANZ firms with in-built biometric technogy The world's only pay-per-use AML platform for legal professionals Not just an AML/KYC tool but offer Pride ourselves on value, support, innovation, Our passive liveness partner ID R&D is globally ranked #1 by NIST. Realaml is ISO and SOC 2. Passive liveiness technoligy is also iBeta 1 & 2 certified.

### **Likely Captured Law Firms Under AU Tranche 2 AML**

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**Category**

**Likely Captured Under AU Tranche 2?**

**Law firms with trust accounts**

✅ Yes – Handling client funds is a key AML risk

**Conveyancing / Property Lawyers**

✅ Yes – Involves high-value transactions

**Corporate / Business Lawyers**

✅ Yes – If assisting with company formation, trust setup, or structuring

**Estate Planning & Trust Lawyers**

✅ Yes – If managing trusts, acting as trustee, or handling client assets

**Litigation & Dispute Resolution Lawyers**

✅ Yes – If managing client funds or settlements

**Family Lawyers**

✅ Yes – If handling property settlements or financial arrangements

**Criminal Lawyers**

❌ No – Generally not handling client funds in transactions

**Employment Lawyers**

❌ No – Typically does not involve financial transactions

**In-house Counsel**

❌ No – Does not provide services to the public

**Barristers**

❌ No – Do not handle client funds

**Government Lawyers**

❌ No – Work for the government, not private clients

### **Global Comparison of AML/CTF Regulations for Law Firms**

This table compares AML/CTF obligations for law firms across **Australia (Tranche 2 - 2026), New Zealand, UK (England & Scotland), Ireland, and South Africa**.

**Tables can't be imported directly. Please insert an image of your table which can be found [here](https://442916559.hs-sites-ap1.com/knowledge-base/preparing-for-austrac-tranche-2-aml/cft-pre-march-31st-realaml-help-center?hsLang=en).**

**Aspect**

**Australia (Tranche 2 - 2026)**

**New Zealand**

**UK (England & Scotland)**

**Ireland**

**South Africa**

**Law Firms Covered?**

✅ Yes (from July 1, 2026)

✅ Yes

✅ Yes (since 2007, expanded in 2017)

✅ Yes (since 2010)

✅ Yes (since 2001)

**Customer Due Diligence (CDD)?**

✅ Yes (from July 1, 2026)

✅ Yes

✅ Yes

✅ Yes

✅ Yes

**Enhanced Due Diligence (EDD) for PEPs?**

✅ Yes

✅ Yes

✅ Yes

✅ Yes

✅ Yes

**Ongoing Monitoring of Clients?**

✅ Yes

✅ Yes

✅ Yes

✅ Yes

✅ Yes

**Suspicious Activity Reports (SARs)?**

✅ Yes (to AUSTRAC)

✅ Yes (to FIU)

✅ Yes (to NCA)

✅ Yes (to FIU)

✅ Yes (to FIC)

**Threshold Transaction Reports (TTRs)?**

✅ Yes ($10,000+)

❌ No

❌ No

❌ No

✅ Yes (R25,000+)

**Independent Audits?**

✅ Yes (from 2026)

✅ Yes

✅ Yes

✅ Yes

✅ Yes

**Risk-Based AML Programs?**

✅ Yes

✅ Yes

✅ Yes

✅ Yes

✅ Yes

**Pre-Existing Clients Require CDD?**

✅ Yes (from July 1, 2026, risk-based)

✅ Yes (risk-based)

✅ Yes (risk-based)

✅ Yes (risk-based)

✅ Yes (risk-based)

**Regulator**

**AUSTRAC**

**DIA**

**SRA / LSRA / Law Society of Scotland**

**Law Society of Ireland**

**FIC (Financial Intelligence Centre)**

**Date of Coverage for Law Firms?**

**From July 1, 2026**

**Since 2018**

**Since 2007 (Strengthened in 2017)**

**Since 2010**

**Since 2001**

### **Key Takeaways**:

- **UK & Ireland**: Have had **Tranche 2-style laws for over a decade**, with AML obligations embedded in **legal practice rules**.
- **New Zealand**: Implemented AML/CTF for law firms in **2018**, under **Phase 2 of its AML Act**.
- **South Africa**: Has regulated **law firms since 2001**, with **strict FIC oversight**.
- **Australia**: **Catching up in 2026**—law firms must **enrol by July 29, 2026** and comply with full obligations **from July 1, 2026**.  
  ​  
  Most **law firms handling client funds and financial transactions** are expected to be captured under **AU Tranche 2 AML** obligations. This includes firms engaged in conveyancing, trust management, and other high-risk legal services.

**UK & Ireland**: Have had **Tranche 2-style laws for over a decade**, with AML obligations embedded in **legal practice rules**.

**New Zealand**: Implemented AML/CTF for law firms in **2018**, under **Phase 2 of its AML Act**.

**South Africa**: Has regulated **law firms since 2001**, with **strict FIC oversight**.

**Australia**: **Catching up in 2026**—law firms must **enrol by July 29, 2026** and comply with full obligations **from July 1, 2026**.  
​  
Most **law firms handling client funds and financial transactions** are expected to be captured under **AU Tranche 2 AML** obligations. This includes firms engaged in conveyancing, trust management, and other high-risk legal services.

Final **exemptions will be clarified in mid-2025**, along with **AUSTRAC’s official guidance** on compliance requirements.  
​

ARNECC vs Tranche 2

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**Requirement**

**ARNECC VOI\***

**Tranche 2 CDD**

**Primary Focus**

Verification of Identity (VOI) for property transactions

Customer Due Diligence (CDD) for AML/CTF compliance

**Regulatory Body**

ARNECC (state-based)

AUSTRAC (federal)

**Primary Verification Method**

Face-to-face with a legally authorized Identity Agent\*

Remote or face-to-face, using risk-based measures

**Remote Verification**

Allowed\* if face-to-face is not possible due to remoteness

Always permitted with risk mitigation

**Who It Applies To**

Lawyers, conveyancers, mortgagees involved in property transactions

Lawyers, accountants, real estate agents, and other designated professions under Tranche 2 AML

**Identity Documents Required**

Set categories based on Model Participation Rules (MPR)

Risk-based approach, identity must be verified per AML/CTF standards

\* ARNECC VOI permits remote verification in cases where face-to-face is not possible, provided additional steps are taken to verify identity.  
​  
​  
Step 1.

### 1. Establish an AML/CTF program

- **ML/TF/PF risk assessment**  
  e.g. the type of work you conduct and the types of clients you deal with
- **AML/CTF policies**

**ML/TF/PF risk assessment**  
e.g. the type of work you conduct and the types of clients you deal with

**AML/CTF policies**

### **2. Appoint an AML/CTF Compliance Office**

Usually an employee within your firm.  
​  
​

​

### **Caveats To Consider**

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**Services**

**Should the Same Vendor Do It?**

Establishing AML/CTF Compliance Program & Staff Training

✅ Yes, same vendor allowed

AML/CTF Independent Audit & Compliance Program Setup

❌ No, independence required

AML/CTF Independent Audit & Staff Training

❌ No, independence required

**Enrol in AUSTRAC**   
If you are providing other newly regulated designated services, the new laws commence on 1 July 2026, and you must enrol by 29 July 2026.   
​  
​  
​  
​**Summary of Key Dates**

**Tables can't be imported directly. Please insert an image of your table which can be found [here](https://442916559.hs-sites-ap1.com/knowledge-base/preparing-for-austrac-tranche-2-aml/cft-pre-march-31st-realaml-help-center?hsLang=en).**

**Date**

**Requirement**

**March 31, 2026**

Risk assessment & AML/CTF compliance policy must be completed.

**July 1, 2026**

Tranche 2 AML/CTF obligations fully in effect & enforced by AUSTRAC.

### **What's Next? Post-**

- [New Zealand](https://help.realaml.com/knowledge-base/new-zealand?hsLang=en)
- [Australia](https://help.realaml.com/knowledge-base/australia?hsLang=en)
- [Canada](https://help.realaml.com/knowledge-base/canada?hsLang=en)
- [General Guides](https://help.realaml.com/knowledge-base/general-guides?hsLang=en)

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