Seven years is longer than your inbox
AML/CTF Tranche 2 commenced on 1 July 2026 and buyer's agents are inside it. There's no sole-trader exemption and no size threshold that gets you out of it.
Most of what's been written since assumes you're the selling agent. A buyer's agent's designated service is a different service. Your customer for AML purposes is the client who engaged you, and the obligation starts at the relationship rather than at settlement. The full picture is here.
The obligation nobody plans for
Enrolment is a form. A program is a document. Training is a morning. Those are the parts that get attention because they have a completion date.
Records have to be kept for around seven years. That one has no completion date, and it's the only obligation on the list that gets harder the longer you succeed at business.
Seven years is longer than most people keep their email, and considerably longer than most people keep a laptop.
Where does a 2026 deal live in 2033?
Answer it honestly for a deal you're running right now. Not where the policy says it lives. Where it actually is.
If the answer involves an inbox, a phone that will be replaced twice by then, a shared drive nobody has audited, and a folder structure only one person understands, that's the gap. And it's a filing problem before it's a compliance problem, which is good news, because filing problems are solvable.
Where Trace sits, precisely
Trace is the record-keeping layer for this, not the compliance engine. It doesn't certify anyone's identity, doesn't run its own sanctions database, and doesn't lodge anything with AUSTRAC on your behalf. The obligation and the judgement call stay yours.
What it does is keep what you checked attached to the client and the deal it belongs to, with a dated, tamper-evident trail of who checked what and when. Dedicated AML tooling is on the roadmap and is not switched on. We'd rather say that than sell a compliance badge we haven't shipped.
If you're weighing dedicated AML software as well, here's where that stops and this starts. If you'd rather start with a checklist, there's one here.
This post is general information about the reforms, not legal or compliance advice, and it isn't a substitute for AUSTRAC's own guidance or your own adviser. Confirm your position before you rely on anything here.
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