InfoTrack Backs a Fair AML/CTF that Works for Everyone

The introduction of Tranche 2 under Australia’s AML/CTF framework represents one of the most significant regulatory shifts the legal and property sectors have faced in decades.

From 1 July 2026, lawyers, conveyancers, real estate agents, accountants, and corporate service providers will be formally designated as reporting entities under the Anti-Money Laundering and Counter-Terrorism Financing Act. The changes will require firms to enrol with AUSTRAC, implement risk-based compliance programs, conduct identity and source-of-funds checks, and report suspicious activity. These obligations have previously applied to financial services providers.

At InfoTrack, we recognise the implications of this for the profession, not just in terms of risk and compliance, but also in terms of daily operations, client service, and overall system integrity. That’s why we’re not just building the tools to help, we’re actively advocating for a compliance model that works for practitioners, not just platforms.
Why Tranche 2 matters now

Expert guest Neil Jeans, Risk Partner at Grant Thornton, explained in a recent AML/CTF webinar hosted by InfoTrack that Tranche 2 is driven by:

• Australia needs to meet global FATF standards to avoid “grey listing”
• A changing threat landscape, with real estate, law and financial advice channels used globally for illicit financial flows
• Legislative catch-up, with gatekeeper professions originally intended to be covered as far back as 2009

Although the legislation was passed in 2024, the regime will officially take effect from July 2026, with enrolment opening on 31 March 2026. But don’t let the timeline fool you, as Neil stressed, time is not your friend. There’s a significant body of work to complete, and a high cost for inaction.

Tranche 2 Requirements

From 1 July 2026, any professional providing a “designated service,” such as brokering a real estate transaction or preparing documents for a conveyance, will be required to:

• Enrol with AUSTRAC
• Conduct a business-wide money laundering risk assessment
• Develop and implement an AML/CTF compliance program
• Appoint a trained compliance officer
• Perform customer due diligence (including source of funds and beneficial ownership checks)
• Report suspicious matters
• Complete annual compliance reporting

The legislation introduces strict financial penalties for non-compliance, including fines of $19,000 per day for failure to enrol within 28 days of providing a designated service.

Practitioners’ sentiment: concerned, overwhelmed, uncertain
The questions raised during the webinar, particularly from sole practitioners and small firms, painted a clear picture: the profession is concerned not about the purpose of the regime, but about its practical implications.

“How does this affect sole practitioners?”
“Can we rely on tech platforms to do the heavy lifting?”
“This feels like we’re being deputised to do the government’s job.”

Neil offered reassurance: Much of what practitioners do already, such as verifying client identities, checking sources of funds, and vetting staff, forms the foundation of AML compliance. However, the burden lies in formalising these processes, documenting them, and reporting them by AUSTRAC standards.

InfoTrack Is Responding with Practical Tools and Strategic Advocacy

At InfoTrack, we’re not waiting for the deadline to act. We are currently in beta with firms as they upgrade to our Verification of Identity tool to meet these new compliance requirements. We will ensure that this capability is available and integrated into your Practice Management Systems well before the July 2026 deadline.

As the regulatory landscape evolves, so will our platform, helping practitioners build defensible compliance programs without the need for costly or complex manual processes. We are currently expanding our compliance solutions to support you. Our new compliance-ready, integrated VOI and onboarding tools, including PEP, Sanctions, and Adverse Media Screening, are in beta and are planned to be available to you in early July.

We will continue to develop best-in-class compliance workflows to ensure you can meet your compliance obligations and minimise disruption within your firm, while maintaining control over meeting the suspicious matter reporting requirements of the AML/CTF obligations.

Our AML/CTF capabilities cover:

• Integrated VOI and onboarding tools
• Sanctions and Adverse Media Screening
• Ultimate Beneficial Owner (UBO) tracing
• Bankruptcy and financial risk checks
• ASIC Company and Business Name extracts
• Risk monitoring

Our Message to Regulators: Preserve Competition, Support the Profession

As the sector prepares for Tranche 2, InfoTrack respectfully urges the Australian Government and AUSTRAC to ensure that the AML/CTF framework supports both compliance and choice. There is growing concern across the industry that some proposals may inadvertently embed a single technology provider as the de facto compliance solution, particularly in areas such as VOI and source-of-funds verification, which could narrow the competitive field.

Centralising critical due diligence checks at the final stages of a transaction before settlement risks introducing operational bottlenecks, increasing exposure to financial crime, and creating an uneven regulatory playing field. This would not only reduce the flexibility practitioners need to implement risk-based compliance measures but also challenge AUSTRAC’s objective of fostering a proactive and adaptable compliance culture.

We encourage government and regulators to reaffirm their commitment to a technology-neutral, open, and competitive compliance environment, one where multiple providers can deliver robust, scalable, and client-aligned solutions. Practitioners deserve the autonomy to select tools that reflect their risk profile, transaction timing, and service model, rather than being compelled into a one-size-fits-all approach.

We remain committed to delivering innovative, compliant solutions that support the legal and property sectors through this reform. We welcome ongoing engagement and collaboration to ensure the Tranche 2 rollout delivers relevant and sustainable outcomes without sacrificing practitioner independence or market fairness. InfoTrack is actively submitting a response to the consultation on behalf of our clients. You too can access the consultation paper and submit your response directly.

You can access InfoTrack’s complimentary AML/CTF training module or watch the Introduction to AML/CTF webinar.

John Ahern
InfoTrack CEO