Tranche 2 AML/CTF for legal practitioners: what the profession is asking, and where to find answers before 1 July

For the past 18 months, InfoTrack has been working directly with Australian law firms and conveyancing practices on what Tranche 2 of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 means for their day-to-day operations. InfoTrack’s AML/CTF Compliance Centre, built specifically for legal and conveyancing clients and available at no additional cost, was developed in direct response to what those conversations revealed: that practices are working through the operational detail of applying a risk-based legislative framework to professional services work that varies enormously in scale, client mix, and transaction type.


Those conversations reflect the genuine complexity of the transition. Practitioners across the country are approaching 1 July 2026 in good faith, and the questions they are carrying are specific, practical, and worth addressing directly.

What is InfoTrack's role in Tranche 2 compliance for Australian legal practitioners?

InfoTrack has supported Australian law firms and conveyancing practices through every significant regulatory transition of the past two decades, from eConveyancing adoption to the evolution of verification of identity requirements. The AML/CTF Compliance Centre extends that support specifically to Tranche 2, giving legal and conveyancing clients an end-to-end compliance solution within the platform they already use.


The Compliance Centre covers firm and staff onboarding, client onboarding, verification of identity, reporting, and ongoing monitoring. It was designed around the way legal and conveyancing work actually flows, and it is available to InfoTrack clients at no additional cost. For practices that are still working through their programme design, or that want to test their current approach against what AUSTRAC will assess, it provides a practical starting point that does not require building or procuring a separate compliance system.

What compliance questions are Australian law firms and conveyancers working through ahead of Tranche 2?

The questions InfoTrack has been hearing from legal and conveyancing clients cluster around four areas where the operational detail requires careful working through at practice level.


The proportionality question is the most consistent. The Act requires a risk-based approach, and practices want to ensure they are drawing the line in the right place for their specific size and service mix. The programme a sole practitioner handling residential conveyancing needs to document differs materially from what a national firm advising on complex commercial and trust structures must put in place, and practices are working through where their own assessment sits.


The suspicious matter reporting obligation intersects with a solicitor’s duty of confidentiality in certain matters. That tension is inherent in the legislation and requires careful navigation, particularly for practitioners working on matters where they hold privileged information.
Beneficial ownership verification does not resolve itself when the trail becomes difficult. Trust structures, multi-layered corporate arrangements, and offshore entities can all produce situations where it is challenging to conduct verification to the standard the Act requires. Practices need documented procedures for those situations, including whether to proceed, seek enhanced information, or decline to act.


And when a solicitor or conveyancer, and real estate agent are all working the same property transaction, each is now a reporting entity with its own obligations. The Reliance framework allows one reporting entity to rely on another’s customer due diligence checks in certain circumstances, but the arrangement must be properly documented, and the relying entity retains responsibility for the outcome. Many practices working in multi-profession transactions are still putting those arrangements in place.

Why does Tranche 2 require a cross-sector approach to AML/CTF compliance?

The reason these questions benefit from a cross-sector conversation is that Tranche 2 arrives into a professional services landscape where the same transaction routinely touches numerous regulated professions, each with a different line of sight into the risk.


Accounting understands the structure of the entity, who owns it, how it is layered, and where the money flows. Real estate controls the mechanics of the transfer, the property, the price, and the transaction itself. Legal and conveyancing hold the identity and intent of the parties, the instructions behind the deal, whilst also executing the settlement.


Each profession has addressed compliance questions within its own industry, and bringing all four into the same conversation produces a vantage point that no single-profession event can offer. That is what makes The Industry Collective Speaks structurally different from anything that has preceded it.

 

What is The Industry Collective Speaks and who should attend?

On 18 June 2026, InfoTrack will host The Industry Collective Speaks, a 90-minute virtual forum that brings all four Tranche 2 professions into a single session for the first time. AUSTRAC, the NSW Law Society, REINSW, Grant Thornton, CA ANZ, and AICNSW will share one panel and one conversation, producing a cross-sector perspective that no single-profession event has been able to offer.

 

AUSTRAC CEO Brendan Thomas will open the forum with a direct address on what a compliant programme looks like in practice, and what the risk-based approach actually demands of Tranche 2 entities across practices of different sizes. Bobbie Wan, Head of Regulatory Policy and Strategy at the NSW Law Society, brings the legal profession’s perspective. Jennie Tonner, President of AICNSW, represents conveyancing. Jill Muir, Senior Policy Advocate at CA ANZ, and Nicole Unger, General Counsel at REINSW, complete a panel that reflects the full transaction chain.

 

Practitioners attending will leave with five specific outcomes:

  1. A perspective not available from any other event, given this is the only forum convening all four Tranche 2 professions simultaneously.
  2. A benchmark for their own readiness, with the ability to understand where their practice sits relative to peers.
  3. Direct clarity from AUSTRAC on the difference between a programme that exists and one that would withstand regulatory review.
  4. Answers to questions requiring careful navigation, including reliance arrangements, the intersection of compliance and client relationship duties, and consumer obligations addressed through real scenarios.
  5. Immediate next steps, supported by post-event sector guides and on-demand resources.

 

1 July is not a soft deadline. A practice that attends on 18 June and acts on what it hears still has a workable window. The event is complimentary and open to all Australian practitioners. An on-demand recording will be available for those who cannot attend live.

 

The forum takes place 18 June 2026, 9:00 am to 10:30 am AEST, via Zoom Webinar. Register now.