The Access Group warns of ‘guidance gap’ ahead of Tranche 2 AML/CTF

Ahead of the fast-approaching start date of the Tranche 2 AML/CTF reforms, The Access Group has urged industry bodies and regulators to provide more comprehensive guidance for accountants to adapt to the incoming rules.

From 1 July 2026, new anti-money laundering and counter-terrorism financing (AML/CTF) rules will impose fresh compliance burdens on a subset of accounting firms.

The expanded AML/CTF regime captures Tranche 2 ‘gatekeeper professions’ such as real estate agents, lawyers and accountants that provide designated services, including assisting with real estate transactions and setting up trust and company structures.

With less than three months to go until the reforms take effect, The Access Group has said that accountants are still feeling unprepared for the new regime, despite AUSTRAC’s efforts to publish starter kits, factsheets and webinars.

“The intent is welcome, but the limitation is real. There is no single, authoritative source that tells a two-partner accounting firm - step by step, service by service, client by client - exactly what to do,” The Access Group noted in a statement.

“What accountants need is scenario-based guidance grounded in actual accounting practice contexts: what a Suspicious Matter Report looks like for a firm that suspects a client is structuring payments to avoid tax obligations, not a hypothetical bank transaction.”

A survey by the organisation of over 1,700 accounting professionals found that only 6 per cent of accountants felt on top of the incoming legislation, with almost a third (32 per cent) reporting that they hadn’t begun to engage with the incoming legislation at all.

The Access Group called on the professional accounting bodies – CPA Australia, CA ANZ and the IPA – to publish further AML/CTF guidance, including worked examples, to support accountants’ understanding of their obligations.

The Access Group’s David Boyar said that the incoming AML/CTF regime was yet another compliance burden for accounting firms, resting alongside other regulatory shifts, including expanded obligations under the Tax Agent Services Act 2009 (TASA).

“This is the latest in a cumulative burden on small practices, and the timeframe for compliance compounds an already significant challenge,” Boyar said.

“The expanded TASA obligations - eight new Code of Professional Conduct requirements – only took full effect for most practices on 1 July 2025. Twelve months later, the same firms must stand up an entirely separate compliance regime.

“Two fundamental reforms to how accountants engage with clients, back-to-back. For small practices with no dedicated compliance resource, the operational pressure is acute. Paper-based processes and manual workflows are not a viable answer.”

Boyar likened the AML/CTF shift to the transition to GST in 2000, warning that businesses that didn’t prepare early could be left scrambling to comply.

“The firms that treated GST as a ‘we’ll figure it out’ problem were the ones scrambling in August 2000. History is about to repeat for anyone not moving now,” he warned.

The Access Group emphasised to practitioners that AML/CTF compliance was not simply a box-ticking exercise, but one that involved material actions and associated documentation, including:

• A written AML/CTF program.
• A designated AML/CTF compliance officer.
• A risk assessment framework covering all designated services.
• Customer due diligence (CDD/KYC) workflows for every client.
• Ongoing transaction monitoring capability.
• Suspicious matter reporting (SMR) procedures.
• Staff training completed and recorded.