The Tranche 2 obligation, in plain terms
A short guide to what changed on 31 March 2026 and what a reporting entity now has to do. Developed with Kestrel Assurance.
What Tranche 2 means for real estate, legal and accounting
A short read on which professions came into the AML/CTF regime on 31 March 2026, and what changes first.
Writing a suspicious matter report that holds up
What the statutory clock actually requires, and why the record matters as much as the report itself.
The Tranche 2 guide
What changed on 31 March 2026
The AML/CTF program provisions moved into Part 1A of the Act. The old “Part A” and “Part B” program split no longer exists, and Tranche 2 professions, including real estate, legal and accounting services, came into the regime alongside existing reporting entities.
The core obligation
Every reporting entity must monitor customers for unusual transactions and behaviours that may give rise to a suspicious matter report. This applies to occasional customers, not just ongoing account holders, and the test is whether information may be relevant to an investigation, not whether an offence occurred.
Screening is a separate obligation
Customers, beneficial owners, and for a remitter, every payer and payee, must be screened against sanctions and PEP lists on a reasonable-grounds basis. A sanctions match on its own is not a suspicious matter report.
The reporting clocks
A suspicious matter report is due 3 business days after suspicion is formed on ordinary grounds, or 24 hours for terrorism financing. Threshold transaction reports on physical currency of $10,000 or more are due within 10 business days.
This guide is general information, not legal advice. For a risk assessment or program review specific to your business, Kestrel Assurance provides the underlying subject matter expertise for Altego.