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March 24, 2026 10 min read

Free Tranche 2 Compliance: How to Meet AUSTRAC Requirements Without Monthly Fees

Tranche 2 takes effect on 1 July 2026 — but compliance doesn't have to cost thousands. Here's how you support a Tranche 2 customer due diligence file with no monthly fee, at any size up to enterprise. Enrolment and reporting stay with you.

The Bottom Line

Using FreeAML with the client-pays option, your total cost for full Tranche 2 compliance is $0/month. The $20 per verification fee is passed to your client. You get AML program generation, identity verification, risk assessments, CDD reports, training modules, and ongoing monitoring — all included.

What Tranche 2 Actually Requires (Plain English)

The AML/CTF Act 2006 (as amended) requires Tranche 2 businesses to do 7 things. Here's each requirement and how to meet it for free:

1

Enrol with AUSTRAC

Requirement: Register as a reporting entity on the AUSTRAC portal

✓ How to meet it free: Free — AUSTRAC enrolment is free via austrac.gov.au

2

Written AML/CTF Program

Requirement: Document your risk-based compliance program with policies and procedures

✓ How to meet it free: Free with FreeAML — auto-generates a branded, AML program for your firm's file based on your business type

3

Customer Due Diligence (CDD)

Requirement: Verify client identity using reliable documents before providing designated services

✓ How to meet it free: Free with client-pays — FreeAML sends verification link, client pays $20, you get compliant CDD report

4

AML/CTF Screening

Requirement: Screen clients against sanctions lists, PEP databases, and watchlists

✓ How to meet it free: Included in every FreeAML check — AML screening, PEP check, and sanctions screening run automatically

5

Risk Assessment

Requirement: Assess the ML/TF risk of each client and your business overall

✓ How to meet it free: Included in every FreeAML check — auto-generates individual risk assessment plus overall business risk assessment

6

Record Keeping (7 years)

Requirement: Retain all CDD records, reports, and correspondence for a minimum of 7 years

✓ How to meet it free: FreeAML takes reasonable measures to retain order and history data so you can download an audit pack for your firm: your program and risk assessment, CDD reports, AUSTRAC reports you prepared, the audit trail, the training register, sanctions checks, and annual compliance reports. Your firm still keeps the records the law requires.

7

Staff Training

Requirement: Ensure all staff understand AML/CTF obligations and can identify suspicious activity

✓ How to meet it free: Free with FreeAML — includes training modules with quizzes and compliance certificates

Who Must Comply with Tranche 2?

From 1 July 2026, these professions become "reporting entities" under the AML/CTF Act:

Real Estate Agents

All agents assisting with buying, selling, or auctioning property. Includes buyer's agents and property developers.

45,000+ businesses

Accountants & Tax Agents

Accountants providing financial services, tax agents, BAS agents managing client funds.

35,000+ businesses

Lawyers & Conveyancers

Legal professionals handling property settlements, trust creation, company formation, and financial transactions.

25,000+ businesses

Dealers in Precious Metals & Stones

Jewellers, gold dealers, and businesses dealing in precious items above $10,000 threshold.

5,000+ businesses

That's over 100,000 Australian businessesthat need AML compliance for the first time. Most are small and medium businesses that can't justify $179-699/month software subscriptions or $5,000+ consultant fees. That's exactly why FreeAML exists.

What Tranche 2 Compliance Costs: 3 Approaches

❌ Approach 1: Hire a Consultant — $5,000-$20,000/year

AML program setup ($3-10k) + manual verifications ($200-500 each) + annual review ($2-5k). Only makes sense for large firms with complex compliance needs.

⚠️ Approach 2: Subscription Software — $2,148-$8,388/year

Monthly fees ($179-699/mo) + per-check fees ($3-15 each). You pay even in months you don't verify anyone. Lock-in contracts common.

✅ Approach 3: FreeAML — $0/month (client-pays) or $20/check

No subscription. No signup. Full AUSTRAC compliance. Pay $20 per check or pass the cost to your client. AML program, risk assessment, training, and record-keeping all included free.

How to Get Tranche 2 Compliant in 30 Minutes (Free)

Here's the fastest path to full compliance:

1

Enrol with AUSTRAC

5 min

Go to austrac.gov.au and register as a reporting entity. Free. Takes 5 minutes.

2

Generate your AML program

2 min

Visit freeaml.com.au and generate your customised AML/CTF program. It's tailored to your profession and business size. Free.

3

Complete staff training

10 min

Go through FreeAML's training modules. Each takes 5-10 minutes and ends with a quiz. Pass and get your compliance certificate. Free.

4

Run your first verification

2 min

Enter your client's email address, choose 'Client pays', and send. They verify in 60 seconds. You get a compliant CDD report. Free for you.

5

Verify every new client

Ongoing

Before every settlement or transaction, send a verification link. FreeAML handles identity checks, AML screening, risk assessment, and record-keeping automatically.

Frequently Asked Questions

Get Tranche 2 Compliant — Free

100 days until the deadline. No signup needed. Just visit FreeAML and start verifying your clients today.

Start Free Compliance