Compliance
Your roadmap to July 2026 AML/CTF compliance
1 June 2026 · 5 min read
From 1 July 2026, Tranche 2 entities — including Australian legal and conveyancing firms — must operate a fully functional AML/CTF program. The work to get there is sequenced, not stacked: each phase unlocks the next.
The table below sets out the key phases, who owns each activity, and when it needs to happen. Treat it as a working backplane for your firm's program build, not a one-off checklist.
| Phase | Activity | Owner | Timing |
|---|---|---|---|
| Phase 1 | ML/TF Risk Assessment customisation | Responsible Officer (RO) | Feb 2026 |
| Personnel roles and AML/CTF governance | Partners / RO | Jan – Feb 2026 | |
| Client policy and onboarding updates | Practice Management | Feb – Mar 2026 | |
| AML/CTF Program documentation | RO | Mar – Apr 2026 | |
| Partner approval | Partners | Apr 2026 | |
| Staff training rollout | RO | May – Jun 2026 | |
| Go-Live | AML/CTF Program operational | All staff | 1 Jul 2026 |
| Phase 2 | Client risk assessment and monitoring | Fee earners | Ongoing |
| Reporting obligations | RO | As required | |
| Phase 3 | Annual program review | RO / Partners | Annually |
| Independent evaluation | External | Every 3 years | |
| Trigger-based updates | RO | As needed |