As we outlined last month in our newsletter from 1 July 2026 Advivo will need to comply with Tranche 2 of the Anti-Money Laundering and Counter-Terrorism legislation.
Australia lags much of the rest of the world in terms of legislation designed to make it more difficult to launder money, engage in the financing of terrorist activities, and fund nuclear and weapons of mass destruction proliferation.
Tranche 2 of the laws expands Australia’s existing framework beyond the banks and finance industry to include:
- Accountants
- Lawyers assisting with transactions
- Company and trust providers
- Real estate
- Precious metals and gemstone dealers
The purpose of this message is to provide you, our valued client, with more information on whether this will affect you and, if so, how it may impact you.
When does this affect you?
The changes may apply in situations such as:
- ASIC registered office (not agent)
- New structure setups — including companies, trusts and partnerships
- Applying for finance — accountant letters may be delayed by several days unless you choose to proceed without them and rely on financial statements and tax returns / notices of assessment already provided
- Buying or selling a business — AML requirements must be completed before we can assist
- Requesting certain referrals (list)
What is not covered by the new legislation?
The following services are not impacted:
- Business accounting, including our MSP/QSP programs
- Annual financial statements
- Tax planning
- Tax returns
- FBT and BAS
We will advise you if you request a service that requires AML/CTF processes to be applied.
When does this start?
From 1 July 2026, Advivo will be required to comply with the new AML/CTF laws.
If you have a transaction underway prior to 1 July that has not been completed by that date, it may fall within the new regime. This may result in additional last-minute costs and potential delays.
Where possible, we will anticipate this in advance and communicate with you to help manage timeframes.
How does this affect you?
You may be required to complete identity checks, including ongoing searches of publicly available information. This may include identifying whether there are adverse media references or whether you are considered a politically exposed person — for example, someone with access to or influence over government decision-making, either in Australia or overseas.
What about the broader impact?
These changes extend AML compliance beyond banking and financial institutions to include accountants, lawyers, company and trust providers, real estate professionals, and precious metals and gemstone dealers.
If your transaction involves more than one of these parties after 1 July 2026, you will be required by law to complete identification processes with each provider.
At present, there is no centralised system that allows this process to be completed once and shared across providers, which may result in additional time and cost.
What will this cost?
Guidance from AUSTRAC is still being progressively released, with detailed requirements only beginning to emerge in recent months.
Whilst we haven’t established yet what this will cost, we do need to advise that for these who we are helping with designated services we will need to pass on the costs of this additional compliance requirement.
What does this mean for you, and what can you do?
In short, these changes are real and unavoidable.
They will introduce additional compliance requirements, which may lead to increased costs and timeframes when engaging in services covered by AML/CTF laws. Where multiple providers are involved, it is likely that each will need to complete their own process.
The most effective approach is to engage advisors early. This can help align timeframes and reduce delays across the transaction. It is also prudent to factor these additional requirements and costs into the feasibility of any project from the outset.
Final thoughts
These reforms are designed to strengthen Australia’s position against financial crime and misuse of business structures. While they introduce additional steps, they also support greater integrity across transactions and professional services.
All parties involved in AML/CTF-regulated services will be required to comply. Attempting to avoid these processes may expose individuals to significant financial and legal consequences, including potential criminal penalties.
We are providing this information now, so you have time to understand and prepare for these changes.
Need assistance?
If you are unsure whether a particular transaction or service will be affected, please contact our office and ask to speak with our AML Compliance Officer, Meredith Holland, or email info@advivo.com.au.
