What is AML/CTF Tranche 2 and does it affect me?

Audience: All members

From 1 July 2026, Australia's anti-money laundering laws extended to professional services firms — including platforms like Smarter SMSF that facilitate trust and company formations. This is known as Tranche 2 of the AML/CTF reforms.

As a result, Smarter SMSF is now a reporting entity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth). This creates formal obligations for us around verifying the identity of firms and individuals accessing certain services.

Does this affect me?

It depends on what you use Smarter SMSF for. The laws apply specifically to what are called "designated services" — services that create new legal entities or transfer control of existing ones.

Ask yourself: do you use Smarter SMSF to order any of the following?

SMSF establishment
LRBA (Bare Trust) setup
Discretionary or unit trust formation
Company incorporation
Changes of trustee

If yes, there is now a compliance step built into the process. If no — if you primarily use Smarter SMSF for pension documents, investment strategies, deed variations, or nominations — nothing changes for you.

What do I need to do?

There are two pathways depending on whether your firm has its own AUSTRAC-registered AML/CTF program:

Pathway A (Reliance Membership) — for firms registered with AUSTRAC as reporting entities. One-time firm verification, then simple per-order attestation.
Pathway B (Full CDD via VerifiMe) — for all other members. No firm setup required. Client verification happens automatically when you place an affected order.

Not sure which applies to you? Contact our team →