13/04/2026
Aleksandar Cankulovski and Andrew Cameron have launched Guardian Compliance, a consultancy dedicated to helping businesses navigate AML/CTF obligations.
Guardian Compliance delivers tailored compliance programs designed to help businesses meet regulatory requirements without compromising commercial outcomes.
The expansion of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 to include Tranche 2 entities represents the most significant shift in Australia’s financial crime framework since the Act first came into force.
If you operate in real estate, conveyancing, precious goods, or certain professional services, these changes will directly impact you.
Many businesses are not yet aware that they are about to become reporting entities.
The scope is broad and includes:
▪︎ Real estate agents and conveyancers
▪︎ Dealers in precious metals and stones
▪︎ Trust and company service providers
▪︎ Lawyers, accountants, and other professionals in specified circumstances
For context, existing reporting entities—such as banks, financial institutions, remittance providers, and casinos—have managed these obligations for years. They typically have established compliance teams, systems, and processes in place.
By contrast, Tranche 2 entities are often starting from scratch, without dedicated compliance resources.
The compliance burden is significant. Requirements include:
▪︎ Registration with AUSTRAC
▪︎ Implementation of AML/CTF programs
▪︎ Customer due diligence
▪︎ Ongoing reporting and record-keeping
▪︎ Civil penalties can reach into the millions, and enforcement action carries serious reputational risks that can materially impact your business.
This series will break down the practical realities of these obligations—from determining whether your business is captured, to implementing a workable and effective compliance framework.
If you are facing this transition and need practical, commercially focused guidance, Guardian Compliance works closely with businesses entering the regime for the first time.
We welcome the opportunity to discuss your specific circumstances.