Back to Blog
March 30, 202615 min read

How to Comply with AML/CTF Tranche 2 for Free (Accountants)

Complete compliance at $0 cost. No consultants, no expensive software, no ongoing fees. Everything you need to meet AUSTRAC obligations by March 31, 2026.

Deadline: March 31, 2026

Criminal penalties apply for non-compliance from July 1, 2026. Maximum: 2 years imprisonment and/or $27,500 fine per breach.

Your Obligations (What You MUST Do)

As an accountant providing designated services (trust account dealings, buying/selling business entities, acting as a formation agent), you're caught by Tranche 2. Here's what AUSTRAC requires:

  1. Register with AUSTRAC by March 31, 2026 (free, takes 10 minutes)
  2. Create an AML/CTF Program - your compliance rulebook
  3. Complete a ML/TF Risk Assessment - identify your risks
  4. Train your team on AML obligations and red flags
  5. Verify all clients when providing designated services (individuals + entities + UBOs)
  6. File reports when required (SMR for suspicious, TTR for $10k+ cash)
  7. Keep records for 7 years (verifications, training, programs)

Key Difference for Accountants: You must verify entities (companies, trusts, SMSFs) AND their Ultimate Beneficial Owners (UBOs). This means:

  • • Individual client = 1 verification ($15)
  • • Company client = Entity verification ($35) + UBO verifications ($15/person)
  • • Trust client = Entity verification ($35) + Trustee + Beneficiaries

How to Do It All for $0

1. AUSTRAC Registration (FREE)

Register at AUSTRAC Online - takes 10 minutes. Follow our step-by-step enrollment guide.

Learn more →

2. AML Program (FREE vs $3,000-7,000)

Use our Program Generator. Accounting-specific template with entity verification workflows. Downloads in 5 minutes.

Learn more →

3. Risk Assessment (FREE vs $4,000-8,000)

AI-powered 20-page risk report. Accounting-specific risks (trust accounts, entity formation, complex structures).

Learn more →

4. Team Training (FREE vs $800-1,500)

4 interactive modules covering UBO verification, red flags, reporting. Certificates included.

Learn more →

5. Client Verifications (FREE for You)

Client-pays model. Individual $15, Entity $35, UBOs $15/person. You pay $0.

Learn more →

6. Reports & Records (FREE)

SMR/TTR/IFTI templates. 7-year storage. Compliance dashboard tracks everything.

Learn more →

Accounting Firm Workflow Example

New company client engaging you for tax services:

  1. 1. Send company KYB link → client pays $35 → company verified
  2. 2. System auto-identifies 2 directors + 2 shareholders (4 UBOs)
  3. 3. Send KYC links to each UBO → each pays $15 → all verified
  4. 4. You pay $0, client pays $95 total, you're fully compliant

Total Cost Comparison

Traditional Compliance

  • AML Program (consultant)$5,000
  • Risk Assessment (consultant)$6,000
  • Training (3 accountants)$3,000
  • Software (easyAML)$299/mo
  • Verifications (50 entities/yr)$2,500
  • First Year Total:$20,088
  • Ongoing (Year 2+):$6,088/yr

FreeAML Compliance

  • AML Program (generator)$0
  • Risk Assessment (AI tool)$0
  • Training (unlimited)$0
  • Software$0
  • Verifications (client-pays)$0
  • First Year Total:$0
  • Ongoing (Year 2+):$0/yr

Save $20,088 First Year

+ $6,088 every year ongoing

Optional: Charge Service Fees (Pro $50/mo)

OPTIONAL

Want to earn revenue from compliance instead of it being a cost? Upgrade to Pro.

  • ✓ Set custom service charges (e.g., $100 per entity verification)
  • ✓ Client sees total price ($35 + your $100 = $135)
  • ✓ You get $100 per check, instant bank payout
  • ✓ Example: 15 entity verifications/month × $100 = $1,500/mo revenue

Real Example: 5-partner accounting firm, 25 new entity clients/month:

25 verifications × $100 markup = $2,500/mo revenue from compliance (covers Pro subscription 50x over)

Explore Pro Features →

Your 30-Minute Compliance Checklist

  1. 1
    Register with AUSTRAC

    ⏱️ 10 min

  2. 2
    Generate AML Program

    ⏱️ 5 min

  3. 3
    Complete Risk Assessment

    ⏱️ 10 min

  4. 4
    Invite team to training

    ⏱️ 2 min

  5. 5
    Send first verification

    ⏱️ 2 min

Total: 29 Minutes

Frequently Asked Questions

Related Free Compliance Guides

Ready to Comply for Free?

Join hundreds of accounting practices using FreeAML for zero-cost Tranche 2 compliance.

Start Free Compliance (29 min) →

No credit card required. No hidden fees. Ever.