Who was in Tranche 1
- Banks, building societies and credit unions.
- Remittance service providers and currency exchanges.
- Casinos, betting agencies and gaming machine venues over a threshold.
- Bullion dealers.
- Superannuation, managed funds, stockbrokers, insurers offering investment products and other financial service providers.
- Later, digital currency exchanges (from 2018).
What they had to do
The same core obligations that apply today: enrol with AUSTRAC, adopt a program (then split into Part A and Part B), identify customers, monitor transactions, report suspicious matters and threshold transactions, keep records and train staff. Large institutions built compliance functions around these rules; the enforcement actions against CBA, Westpac and the casinos were for failures in exactly these areas.
Why the professions were left out
The 2006 Act was always intended to be followed by a second tranche covering lawyers, accountants, real estate agents and dealers in high-value goods, which international standards (the FATF Recommendations) already required. Successive consultations from 2007 onwards stalled over cost, privilege and lobbying. The FATF's 2015 evaluation of Australia rated it non-compliant on these sectors, and pressure mounted until the Amendment Act 2024.
What Tranche 1 entities should know about the reforms
The 2024 amendments also changed the rules for existing reporting entities from 31 March 2026: a single AML/CTF program structure built on a risk assessment and policies, updated customer due diligence rules and new rules for virtual assets and value transfers. The reformed tipping-off offence started earlier, on 31 March 2025, and threshold transaction and suspicious matter reporting for existing entities stays as it was until 2029. Existing entities have had to update programs, not just newcomers.
Questions people ask
- Is my bank in Tranche 1?
- Yes. All authorised deposit-taking institutions have been reporting entities since 2007.
- Did Tranche 1 include accountants who also gave financial advice?
- Only for the financial services that were designated, such as dealing in securities. Accounting services themselves were not designated until Tranche 2.
Sources
Official AUSTRAC guidance this page was checked against. The date is when we captured the page; AUSTRAC may have updated it since.
- Summary of changes for current reporting entities (Reform) · AUSTRAC, captured 01 Dec 2025
- New AML/CTF Rules · AUSTRAC, captured 27 Dec 2025
- Tipping off · AUSTRAC, captured 16 Nov 2025
- Enforcement actions taken · AUSTRAC, captured 16 May 2026
General information about Australian AML/CTF law, not legal advice. The Act, the Rules and AUSTRAC's guidance are the primary sources.