Are financial advisers who deal with retirees covered under Tranche 2?

Most financial advisers giving advice to retirees won't be caught by Tranche 2. The reason: AFSL-holding financial advisers are already captured under Tranche 1 of the AML/CTF Act for the financial product advice and product issuing activities they perform. They're already reporting entities, already required to enrol, already required to perform CDD on clients receiving designated services. Tranche 2 doesn't add a second layer of obligation on the advisory activity itself.

Where additional Tranche 2 obligations could apply:

The adviser also performs trust or corporate structuring (Table 6, items 4-6).
The adviser holds an interest in or acts as nominee for client assets outside the AFSL regime.
The adviser's firm offers tax or accounting services in parallel.

For most pure financial-advice practices, the existing AFSL/Tranche 1 position is the controlling framework and no new Tranche 2 enrolment is required.

For the customer-facing summary, see HubSpot KB: https://knowledge.easyaml.com/questions-regarding-designate

Are financial advisers who deal with retirees covered under Tranche 2?

Most are not, because AFSL holders are already captured under Tranche 1; additional Tranche 2 coverage only applies if they also provide TCSP or trust services.

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