With tranche 2 AML/CTF reforms approaching, conveyancers and legal practitioners are turning their focus to what compliance will look like in practice and where to begin.
The requirements may seem complex at first, but the path forward is more structured than it appears. Drawing on AUSTRAC guidance, these obligations can be broken down into five compliance components. This blog dives into what each component means and what your firm is required to do.
The 5 essential components of compliance
1. Enrolling with AUSTRAC
Businesses that deliver designated services are required to register with AUSTRAC within 28 days of commencing those services. For tranche 2 organisations, the enrolment window opens on 31 March 2026. During registration, AUSTRAC will request details about your organisation and its key decision-makers or responsible officers.
2. Onboarding your firm and people
Firms must demonstrate a clear understanding of their risk exposure, maintain a compliant AML/CTF Program, and ensure staff are appropriately trained to carry it out.
- Risk assessment: Organisations are required to assess their exposure to money laundering and terrorism financing risk at a firm-wide level. This assessment determines the controls and oversight required and forms the foundation of the AML/CTF Program, which must be regularly reviewed and kept up to date.
- AML/CTF program: All practices are required to have a written AML/CTF Program outlining how they identify, manage, and mitigate ML/TF risks. This should cover governance and staff responsibilities, firm-wide risk assessment, client due diligence, training procedures, and other key processes.
- Personnel due diligence: Firms must ensure all employees involved in AML/CTF activities are suitable, verified, and trained.
- Staff training: Firms must ensure all staff clearly understand their AML/CTF responsibilities and are capable of identifying, assessing, and managing ML/TF risks.
3. Onboarding your customers
A key part of tranche 2 is ongoing customer due diligence. All entities must complete structured due diligence before providing a designated service. Firms must gather enough information to know their customer, understand the purpose of the engagement, and assess any ML/TF risks. This includes collecting identification information, funding details, looking for suspicious activities, and more.
Once onboarding information is collected, entities must verify customers and related parties using reliable and independent checks. You also need to perform a risk assessment for each customer and keep records of all onboarding, verification, and risk assessment activities.
4. Reporting to AUSTRAC
5. Record keeping
AUSTRAC requires entities must maintain clear, complete, and auditable records of every step, from customer onboarding to reporting suspicious activity for at least 7 years.
How to make AML/CTF compliance more managable
AML/CTF compliance requires firms to complete a range of tasks, from onboarding customers to keeping records and meeting reporting obligations. Managing these requirements across multiple systems or manually can become time-consuming and harder to maintain consistently. So, how can compliance be managed in a more structured and practical way?
An integrated compliance solution brings all activities into one place. The triSearch Compliance Centre is built directly into triConvey, guiding you through the full compliance lifecycle.
With the Compliance Centre, you can:
• Enrol with AUSTRAC
• Complete firm risk assessments and establish your AML/CTF program
• Perform customer due diligence
• Manage reporting obligations
• Maintain compliant records for up to 7 years
There is no need for additional systems or separate compliance tools. All AML/CTF processes connect in one place, making it easier to oversee transactions, track obligations, and manage compliance tasks efficiently. Explore how triSearch can support your tranche 2 requirements in our ‘Your 5-step Guide to AML/CTF Compliance’ eBook.
