
Tranche 2 AML/CTF: An Early Temperature Check for Professional Service Providers
Australia’s Tranche 2 AML/CTF reforms moved into live operation on 1 July 2026. One month later, the evidence is not strong enough for a verdict - but it is sufficient to identify the questions that matter. This article explains why scope mapping remains the first control, clarifies the significance of the 29 July enrolment deadline, and examines the shift from having policies and templates to operating an effective AML/CTF framework. It also considers the position of governance and company secretarial providers, the need to integrate customer due diligence into ordinary workflows, the interaction between recordkeeping and privacy, and the responsibilities of governing bodies, senior managers and compliance officers. The central lesson is that commencement readiness is not completion: the next phase is to test, evidence and improve how the program works in live engagements.


