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 to meet every AUSTRAC requirement using free tools, and what a fully compliant setup looks like for small and medium businesses.
The Bottom Line
Using FreeAML with the client-pays option, your total cost for full Tranche 2 compliance is $0/month. The $15 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, AUSTRAC-compliant AML program 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 $15, 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: Free with FreeAML — all records stored securely with instant search and export
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 $15/check
No subscription. No signup. Full AUSTRAC compliance. Pay $15 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 or mobile, 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.
Frequently Asked Questions
Get Tranche 2 Compliant — Free
100 days until the deadline. No signup needed. Just visit FreeAML and start verifying clients today.
Start Free Compliance