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:
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
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
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
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
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
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.
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:
Enrol with AUSTRAC
5 minGo to austrac.gov.au and register as a reporting entity. Free. Takes 5 minutes.
Generate your AML program
2 minVisit freeaml.com.au and generate your customised AML/CTF program. It's tailored to your profession and business size. Free.
Complete staff training
10 minGo through FreeAML's training modules. Each takes 5-10 minutes and ends with a quiz. Pass and get your compliance certificate. Free.
Run your first verification
2 minEnter your client's email address, choose 'Client pays', and send. They verify in 60 seconds. You get a compliant CDD report. Free for you.
Verify every new client
OngoingBefore every settlement or transaction, send a verification link. FreeAML handles identity checks, AML screening, risk assessment, and record-keeping automatically.
Related articles
Tranche 2 for real estate agencies
How you meet customer due diligence on a sale, purchase, or transfer without a monthly fee.
Tranche 2 for accounting firms
How you meet customer due diligence on designated accounting services without a monthly fee.
Tranche 2 for conveyancers
How you meet customer due diligence on a settlement file without a monthly fee.
Tranche 2 for precious metal dealers
How you meet customer checks and cash-transaction monitoring without a monthly fee.
Tranche 2 for financial services
How you meet customer due diligence when advice includes entity work, without a monthly fee.
AUSTRAC enrolment checklist
Documents and details to gather before you open the enrolment form.
Tranche 2 obligations
Who the rules cover, and the seven obligations you still own.
📚 Related Resources
Free KYC Check →
Verify customer identity in 60 seconds. Government ID + AML screening.
Free AML Program →
Board-ready AML/CTF Program template. All 10 AUSTRAC sections included.
Risk Assessment Generator →
AI-powered ML/TF risk assessment. 20-page compliant report in 5 minutes.
Free AML Training →
Online courses for staff. CPD-certified certificates included.
AUSTRAC Reporting Tools →
File SMRs, TTRs, IFTIs directly to AUSTRAC. Pre-filled forms.
Frequently Asked Questions
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