The AML Advisory Dating Game

Queue Jump Now or Queue Forever

A smart person learns from their mistakes - a wise one learns from New Zealand’s.

When New Zealand rolled out its Phase 2 AML/CFT obligations back in 2018–2019, things got awkward pretty quickly. Real estate agents, lawyers and accountants were all scrambling to find someone - anyone - who could help them get AML ready before the deadline. It was like Tinder for compliance. Everyone suddenly realised they were single and the AML advisors were the hottest bachelors in town.

Lawyers had to go live by 1 July 2018, accountants by 1 October, and real estate agents by 1 January 2019. As New Zealand’s Law & Order Committee politely noted, “some submitters expressed concern that the proposed timeframes were too short, and worried about being ready to meet their new obligations.” which is code for ‘nobody was ready and everyone was freaking out.’

Now it’s Australia’s turn. Over 90,000 new Tranche 2 reporting entities including law firms, accountants and real estate agents are about to start swiping right on AML advisors. The problem? There aren’t enough to go around. By mid-2026, AUSTRAC expects everyone to be enrolled and compliant. Translation: if you wait until next year, the good ones will already be taken.

So don’t rush to get married, just get to first base before Christmas. Meet an AML advisor. Have a chat. Maybe share your risk appetite over coffee. You don’t need to exchange program documents on the first date, but you do need to start building the relationship. 

Because come March 2026, the queues will be long, the advisors will be booked solid, and you’ll be left saying, “It’s not you, AUSTRAC, it’s me...”