Tranche 2 self-check

Is your practice caught by Tranche 2?

From 1 July 20261, law firms providing any of nine specific services2 must have a working AML/CTF program in place. Use this 60-second check to find out if you're captured.

Tick any service your firm provides, or expects to provide after 1 July 2026.

Include work you do occasionally, pro bono, or for friends and family. There is no minimum threshold and no "primary business" exemption.3

For barristers: services you provide on instructions from a solicitor are not designated services under s.6B of the Act, the obligation sits with the instructing solicitor's firm. The check below applies only to any direct work you take outside that arrangement.5

Two traps to watch, even if you ticked nothing3

The "incidental" trap. There is no "primary business" exemption. If your firm is mostly family law but you handle one property settlement a year, you are captured for that work.

The "free" trap. Pro bono work and favours for family count, if they are done in the course of carrying on your business.

The "advising vs assisting" line. Providing strategic advice on a proposed structure is generally not captured. Taking concrete steps to execute the transaction (drafting transfer documents, moving funds, registering an entity) is. The line can be subtle, and AUSTRAC's guidance should be your reference point.4

The barrister exemption. If you're a barrister, services you provide on instructions from a solicitor are not designated services (s.6B of the Act, the obligation sits with the instructing solicitor's firm). Only direct work you take outside that arrangement is potentially caught.5

If you are unsure where the line falls for your work, treat yourself as captured and confirm it with a compliance professional.

Sources

  1. 1 July 2026 commencement for Tranche 2 entities. AUSTRAC, Summary of AML/CTF obligations for Tranche 2 entities. austrac.gov.au. Note: enrolment for newly regulated industries opens 31 March 2026; you must enrol by 29 July 2026 if you provide a captured service.
  2. The nine designated services for legal practitioners. Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), section 6, subsection (5B), Table 6. See AUSTRAC's plain-English overview at Professional designated services (AUSTRAC). The wording in this tool is adapted from the Act and from AUSTRAC's published guidance for the legal sector.
  3. No minimum threshold, no "primary business" exemption, pro bono and one-off work counts. AUSTRAC, Legal profession program starter kit (January 2026 release). austrac.gov.au — Legal profession starter kit, Getting started.
  4. The "advising vs assisting" distinction. AUSTRAC's guidance states that whether activities relate to providing a Table 6 designated service depends on the facts of each case, and addresses the meaning of "assisting or otherwise acting for or on behalf of a person" for items 1–4 and 6. See Professional designated services (AUSTRAC). If the answer matters to your practice, get specific advice.
  5. The barrister exemption (s.6B). Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), section 6B: a service is not a designated service if it is provided by a person in the course of legal practice as a barrister on the instructions of a solicitor. See the Act at AustLII — AML/CTF Act 2006, s.6 (and surrounding sections). If you take direct work outside solicitor instructions, the exemption may not apply to that work; get specific advice if you're unsure.

Tool reviewed: May 2026. References reflect AUSTRAC guidance current at that date. Source links open in a new tab. Please verify links resolve and content is current before publication.