Now is not the time to sit on your hands

In October 2025 AUSTRAC released its core guidance to support businesses in preparing for the major changes to Australia’s AML/CTF regime.

This guidance is available on AUSTRAC’s website: https://www.austrac.gov.au/about-us/amlctf-reform

The purpose of this guidance is to clarify how the revised obligations will apply, describe what good looks like under the new regime and help both current reporting entities and newly-regulated sectors to begin the transition.

Why This Matters for Tranche 2 Entities

If your business is in a sector soon to be regulated including real estate, legal services, conveyancing, accounting or precious metals, this guidance is a critical first step. It provides insights into:

• how AUSTRAC interprets key terms under the re-worked law and rules,

• what AUSTRAC expects in terms of governance, risk assessment, customer due diligence and program design,

• the timeline of upcoming obligations and next steps in the reform process.

However, if you are in real estate, law, accounting or conveyancing, you will be waiting for the industry-specific guidance that AUSTRAC has signalled will arrive in early 2026.

Don’t Use the Wait as a Delaying Tactic

While the industry specific guidance will be very useful, it should not be an excuse for inactivity. With more than 90,000 businesses expected to fall under regulation in the first half of 2026, the demand for AML advisory capacity will be intense.

The timeline to keep in mind:

• 31 March 2026: enrolment opens for newly-regulated entities (Tranche 2)

• 1 July 2026: full compliance obligations begin for those new entities.

Given this timeline, waiting for the industry-specific guidance before doing anything could put your business under pressure both in terms of compliance readiness and access to expert advisory support.

What You Should Be Doing Right Now

Here are practical steps to use this newly published guidance to your advantage:

1. Read and digest the core guidance: Start with the core guidance AUSTRAC released, understand the expectations around risk-based compliance, program design and how the law is interpreted.

2. Map your services and check if you will be regulated: Even before the sector specific guidance arrives, you should determine whether your business provides designated services (or ‘assists’ with them) and whether the regulatory regime will apply to you.

3. Begin building your internal compliance framework: Use this time to identify

• Who in your business will take responsibility for AML/CTF compliance?

• What your risk assessment will look like (customers, services, delivery channels, geography)?

• Which policies, procedures and training you will need.

• How your current systems compare with the expectations in the new guidance.

4. Plan for the advisory-capacity crunch: Given the volume of businesses entering the regime, AML advisors and consultants will be in high demand. Getting ahead of the pack now gives you choice and reduces the risk of being caught behind a queue of firms all trying to engage specialist help in early 2026.

Final Thoughts

The October 2025 guidance from AUSTRAC is a strong signal that the reform program is moving into the implementation phase. The core expectations are now clear. While the industry-specific guidance for sectors such as real estate, law and accounting is still to come, businesses in those sectors should treat the arrival of the core guidance as a starting gun and not a pause button.

By acting now to assess risk, map obligations and build your compliance framework, you will position yourself for a smoother transition when your sector specific guidance lands. Delay too long and you risk being left behind, with less time, fewer advisory options and higher pressure on your business.

Or just call Agentic AML and we'll get you going, keep you on track and then you'll be sure to have robust, cost effective AML compliance in place by the 1 July 2026 deadline.