By My CPE Pty Ltd | February 2026
From 1 July 2026, many tax and BAS practices will be treated as “Tranche 2” entities and brought into Australia’s expanded Anti‑Money Laundering and Counter‑Terrorism Financing (AML/CTF) regime. If your practice provides designated services, you will be expected to have a robust, documented AML/CTF framework in place – not just a generic policy sitting on the shelf.
The countdown has started, and the practices that act early will be the ones that move smoothly into the new regime.
What’s Changing for Tax and BAS Agents?
Under the Tranche 2 reforms, certain services typically provided by accountants, tax agents and other professional firms will be regulated by AUSTRAC for AML/CTF purposes. If your practice provides designated services, you will need to comply with a set of new obligations that go well beyond existing professional and ethical standards.
In practice, this means you may need to:
- Enrol with AUSTRAC as a reporting entity once enrolment opens (scheduled from 31 March 2026) and by the July 2026 deadline.
- Appoint an AML/CTF Compliance Officer at management level to oversee implementation and ongoing compliance.
- Develop and maintain a written, risk‑based AML/CTF Program tailored to your services, client base and delivery channels.
- Conduct initial and ongoing customer due diligence, identify beneficial owners and screen for politically exposed persons (PEPs).
- Implement a client risk assessment framework and transaction monitoring processes to detect unusual patterns, red flags and suspicious matters.
- Lodge Suspicious Matter Reports (SMRs) and any other required reports to AUSTRAC within strict timeframes.
- Keep comprehensive AML/CTF records (including risk assessments, due diligence and reporting evidence) for at least seven years.
Non‑compliance is not a “soft launch” issue – AUSTRAC has a full toolkit of civil penalties, infringement notices, remedial directions and, in serious cases, court‑ordered sanctions and referrals for criminal investigation.
Why AML/CTF Compliance Matters for Your Practice
For many smaller tax and BAS practices, AML/CTF might feel like “something the banks do”, but Tranche 2 deliberately brings professional gatekeepers such as accountants and tax advisers into line with global standards. Your work in setting up structures, handling client funds, and advising on complex transactions makes you a target for those trying to hide or move illicit wealth.
Getting AML/CTF right is about more than avoiding penalties:
- Protecting your registration: Regulators increasingly expect aligned conduct between professional standards, tax law and AML/CTF compliance.
- Protecting your reputation: A single high‑profile breach or enforcement action can permanently damage client and referral relationships.
- Protecting your clients: Robust controls help you spot red flags early and avoid becoming entangled in criminal activity, disputes or investigations.
AML/CTF compliance is now part of contemporary practice management, not an optional add‑on.
Want to Learn More?
To support practices through this transition, we’ve developed a practical, TPB‑compliant online course designed specifically for tax and BAS practitioners who will be captured under the Tranche 2 reforms. The course focuses on what you actually need to do in a day‑to‑day practice environment, not just theory or legislative citations.
Course snapshot:
- Title: AML/CTF for Practice Management
- Format: Online e‑Learning (self‑paced)
- Duration: 3 hours (3 structured CPE hours)
- Assessment: Short quiz to consolidate key concepts
- TPB‑compliant: Yes
- Course fee: $165 (incl. GST)
By the end of the course, you will understand:
- The AML/CTF legal and regulatory framework as it applies to Tranche 2 tax and BAS practices.
- AUSTRAC’s role as regulator and its powers to monitor, investigate and enforce compliance.
- What a compliant, risk‑based AML/CTF Program looks like for a professional services firm.
- How to identify suspicious matters, including common indicators and practical detection methods in a tax or BAS context.
- How SMR and other reporting obligations work in practice, including key deadlines and submission expectations.
- The consequences of getting it wrong – from penalties and remediation through to reputational damage and regulatory scrutiny.
This is not a “set and forget” webinar – it is structured to help you start designing and implementing your own AML/CTF framework as you learn. Enrol here: https://course.mycpe.com.au/plus/catalog/courses/373
Why You Should Start Preparing Now
Building AML/CTF capability in your practice takes time. Even a smaller firm will need to allocate capacity for risk assessments, policy and procedure development, system changes, staff training and cultural change.
Starting now allows you to:
- Map which of your services are likely to be designated and confirm if you are a Tranche 2 reporting entity.
- Appoint and upskill your AML/CTF Compliance Officer early, so they can lead the implementation.
- Develop a tailored AML/CTF Program that integrates with your existing quality, tax and practice management systems.
- Train your team so they understand red flags, escalation points and their own responsibilities.
- Road‑test your processes before the regime becomes fully enforceable on 1 July 2026.
Investing just a few hours now can save you weeks of reactive work and stress as deadlines approach.
Ready to Get AML‑Ready?
If you want guidance that is tailored to how tax and BAS practices really operate, our team is here to support you from first questions through to implementation.
Book a consultation to talk through your current position, services, and risk profile, and get help choosing the right learning pathway for your team.
Visit our website to explore full course details, review enrolment requirements, view success stories and access additional AML/CTF resources.
When it comes to Tranche 2, the opportunity is here, the pathways are clear, and the support is ready – the next move is yours.