A change came into force on 1 July that has already shifted how a lot of professional services businesses run. Depending on what you do, or who you deal with, it either applies to you now or it changes the way you deal with your lawyer, accountant or real estate agent.

The change is the AML/CTF “Tranche 2” reform. Obligations that have applied to banks and casinos for years now extend to lawyers, accountants, real estate agents, conveyancers, property developers, and trust and company service providers. If you sit in one of those professions, or your business offers any of those services as part of a wider mix, this is the law you’re operating under right now.

If you’re newly captured, one date has already passed and it matters. Newly regulated businesses had until 29 July to notify AUSTRAC of their appointed compliance officer. If that landed on your desk and you haven’t dealt with it, move now. The penalties are real, into the millions for a body corporate. The harder problem sits underneath: customer due diligence, ongoing monitoring, suspicious matter reporting and record keeping. None of it can be bolted on after the fact.

Here is where it reaches you even if none of that applies to your business directly. If you’re planning to buy or sell property, restructure, set up a trust, or bring in a lawyer or accountant to help with a transaction, you’ll feel the change from the other side. Expect more questions about identity, ownership and the source of your funds than you’re used to. Those questions are the law now. Your adviser has to ask, verify and keep a record of the answer, whether they want to or not.

We’ve watched this play out before in other corners of financial services, and it tends to run the same way. Early on it feels like friction. A few months in it’s simply how things are done, and the businesses that treated it as a real governance upgrade came out with cleaner structures and tighter internal discipline than they had going in.

It’s worth being clear about what this is for. Tranche 2 closes a gap. Property deals, trust structures and company formations have been an easier channel for laundering money than they should be, and the reform is built to shut that down. For anyone running a business through a trust, or planning a sale or acquisition in the next year or two, the flow-on is plain: your structure and your paperwork have to stand up to more scrutiny than they used to.

If you’re not sure whether Tranche 2 catches your business directly, or what it means for a deal you’ve got coming up, it’s worth a conversation now rather than later. This is far easier to get ahead of than to untangle once a deal is moving and someone starts asking questions you didn’t see coming.

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