AUSTRAC Compliance

How to Comply with AUSTRAC Tranche 2 Requirements: Complete Guide 2026

From July 1, 2026, 45,000+ Australian businesses must comply with AUSTRAC Tranche 2 requirements. This guide covers everything you need: customer verification, AML programs, risk assessments, training, and reporting.

📅 Updated: March 30, 2026⏱️ 15 min read✍️ By FreeAML Compliance Team

Critical Deadline: July 1, 2026

All Tranche 2 businesses must be fully compliant by this date. Penalties for non-compliance include fines up to $27 million and imprisonment up to 10 years.

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Who Must Comply with Tranche 2?

If your business falls into any of these categories, you must comply with AUSTRAC Tranche 2 requirements:

Real estate agents (45,000+ agencies)
Accountants and tax agents (40,000+)
Lawyers and conveyancers (25,000+)
Trust and company service providers
Jewellers and precious metal dealers (3,000+)
High-value dealers (cars >$10k, boats, art)

Step 1: Enroll with AUSTRAC (Before July 1, 2026)

Timeline: Must be completed before providing any designated services after July 1, 2026.

What You Need:

  • Australian Business Number (ABN)
  • Business details (address, industry, services)
  • Compliance officer details (name, contact)
  • Director/principal identification

Step 2: Create Your AML/CTF Compliance Program

Your AML/CTF program is a written document outlining how your business will identify, manage, and mitigate money laundering and terrorism financing risks.

Free AML Program Generator

Generate a complete, AUSTRAC-compliant AML/CTF program in 5 minutes. Customized for your industry with all required sections.

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Your Program Must Include:

  1. 1

    Part A: Customer Due Diligence (CDD) Procedures

    How you'll verify client identities before providing services

  2. 2

    Part B: Ongoing Customer Due Diligence

    How often you'll re-verify clients and monitor transactions

  3. 3

    Part C: Designated Service Assessment

    Which of your services require AML compliance

  4. 4

    Part D: Risk Assessment

    Your business's ML/TF risk profile and mitigation strategies

  5. 5

    Part E: Compliance Officer Appointment

    Who is responsible for AML compliance in your business

  6. 6

    Part F: Staff Training Program

    How and when staff will be trained on AML obligations

  7. 7

    Part G: Record Keeping

    How you'll store records for 7 years as required

Step 3: Conduct ML/TF Risk Assessment

AUSTRAC requires you to assess your business's exposure to money laundering and terrorism financing risks. This assessment informs your compliance program.

Risk Factors to Assess:

Customer risk (high-net-worth, PEPs, foreign nationals)
Service risk (cash transactions, international transfers)
Geographic risk (high-risk countries)
Product/delivery risk (remote services, third parties)

Free Risk Assessment Tool

Answer 15 questions about your business and get a complete 20-page ML/TF risk assessment report. Instantly downloadable, fully AUSTRAC-compliant.

Complete Free Assessment →

Step 4: Implement Customer Due Diligence (CDD)

Before providing designated services to a client, you must verify their identity and assess their ML/TF risk. This is called Customer Due Diligence (CDD).

What CDD Requires:

For Individuals:

  • • Full name and date of birth
  • • Residential address
  • • Photo ID verification (driver licence, passport, Medicare)
  • • Biometric liveness check (selfie matching photo ID)
  • • AML watchlist screening (PEPs, sanctions, adverse media)

For Companies/Trusts:

  • • Entity name and registration details (ACN/ABN)
  • • ASIC extract or trust deed
  • • Director and shareholder identification
  • • Beneficial owner verification (25%+ ownership)
  • • Corporate AML screening

💡 FreeAML: AUSTRAC-Compliant CDD in 60 Seconds

Send your client a verification link via email or SMS. They complete ID verification on their phone in under 2 minutes. You receive an AUSTRAC-compliant CDD report instantly.

Individual KYC

$15

Company KYB

$35

Client Pays

FREE

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Step 5: Train Your Staff

All staff who interact with clients or handle transactions must complete AML/CTF training. Training must be completed before July 1, 2026 and refreshed annually.

Training Must Cover:

  • AML/CTF Act obligations and penalties
  • How to verify customer identity (CDD procedures)
  • Recognizing suspicious transactions
  • How to report suspicious matters to AUSTRAC
  • Record keeping requirements (7 years)
  • Your business's compliance program

Free AML Training Modules

4 comprehensive training modules with quizzes and certificates. Takes 2 hours total. Print certificates for your compliance records.

Start Free Training →

Step 6: Set Up Transaction Monitoring

You must monitor client transactions for suspicious activity. Red flags include:

Large cash transactions (>$10,000)
Frequent just-below-threshold transactions
Transactions inconsistent with client profile
Rapid movement of funds
Refusal to provide identification
Unusual international transfers

Step 7: Report to AUSTRAC

You must report certain transactions and suspicious matters to AUSTRAC:

🚨 Suspicious Matter Report (SMR) - Within 24 hours

If you suspect a transaction involves money laundering or terrorism financing, you must report it within 24 hours of forming the suspicion.

💰 Threshold Transaction Report (TTR) - Within 10 days

Report any cash transaction of $10,000 or more within 10 business days.

🌏 International Funds Transfer Instruction (IFTI) - Within 10 days

Report any international money transfer within 10 business days.

Free AUSTRAC Report Templates

Pre-filled templates for SMR, TTR, and IFTI reports. Fill in the blanks and submit directly to AUSTRAC Online.

Get Free Templates →

Cost of Tranche 2 Compliance

With FreeAML: $1,800/year (10 verifications/month)

AUSTRAC enrollmentFREE (DIY)
AML/CTF program creationFREE (Generated)
ML/TF risk assessmentFREE (Tool)
Staff training (4 modules)FREE (Online)
Report templates (SMR/TTR/IFTI)FREE (Templates)
Customer verification (10/mo)$1,800/yr ($15 each)
Total Annual Cost:$1,800

Compare to traditional AML software: easyAML ($2,148/yr), First AML ($3,600+/yr), Australia Post ($5,880/yr). FreeAML saves you 24-69% annually.

Penalties for Non-Compliance

⚠️ Serious Consequences

  • Criminal prosecution

    Up to 10 years imprisonment for serious breaches

  • Corporate fines

    Up to $27 million for companies

  • Individual fines

    Up to $5.4 million for individuals

  • Infringement notices

    $20,000-$100,000 on-the-spot fines

  • Enforceable undertakings

    Court-ordered compliance actions

  • Professional deregistration

    Loss of license to operate

Timeline: When to Start

Now - April 2026

AUSTRAC enrollment, program creation, risk assessment

April - May 2026

Staff training, test CDD procedures, set up reporting

May - June 2026

Final testing, compliance audit, system checks

July 1, 2026

Go live - full compliance required

💡 Recommended: Start now. Don't wait until June to begin compliance. Many businesses are starting early to avoid the July rush.

Start Your Tranche 2 Compliance Today

Generate your AML program, complete risk assessment, train your staff, and verify your first client — all in one afternoon. Completely free to start.

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Frequently Asked Questions

Do I really need to comply if I'm a small business?

Yes. The AML/CTF Act applies to ALL businesses providing designated services, regardless of size. A sole trader real estate agent has the same obligations as a large agency.

Can I use free tools for Tranche 2 compliance?

Yes. FreeAML provides all required compliance tools for free: program generator, risk assessment, training, and report templates. You only pay $15 when you need to verify a client's identity.

What if I miss the July 1, 2026 deadline?

You cannot legally provide designated services without compliance. Operating non-compliant risks criminal prosecution, multi-million dollar fines, and loss of professional registration.

How long does it take to become compliant?

With FreeAML's free tools, you can complete your program, risk assessment, and staff training in 4-6 hours total. Most businesses become fully compliant in 1-2 weeks.