The new laws will come into force on 1 July 2026.

Bowler and Waller said the 2026 launch of Tranche 2 of the AML/CTF regime, which is aimed at strengthening the regime to deter, detect and disrupt money laundering, would implement some of the most significant regulatory reforms in years.

“Importantly, it’s not about who you are, it’s about what you do,” Bowler said.

“Those AFS licensees who are currently caught by the AML/CTF regime and rely on the ‘item 54 designated services’ exemption, may no longer be able to rely on the exemption and will be required to comply with all AML/CTF obligations.”

She continued that financial advisers who are eligible to continue operating under the exemption will be required to update their existing policies and procedures to comply with the amended requirements by 31 March 2026.

“No different to accountants, it means all financial advisers must reassess the services they provide against the new designated services,” Bowler added.

Bowler and Waller said it was imperative for accountants and advisers to identify how the new regulations will affect their businesses to determine if they will be regulated and what they need to do to ensure they are compliant with their obligations. This is important to mitigate business risks and avoid potential penalties for non-compliance.

“They need to begin making key decisions now so they can start taking steps to develop and implement an effective compliant framework tailored to their practice,” they said.

“It will be critical not to leave it until the last minute. If they provide a designated service before enrolling, there’s only 28 days to enrol and comply with a range of statutory obligations to avoid civil penalties. Don’t think this is a 2026 problem – there are practical steps to take now for a smoother transition to the new regime.”

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