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From 1 July 2026, Tranche 2 entities that provide “designated services, including accountants, trust and company service providers (TCSP), dealers in precious stones, metals and products, lawyers, conveyancers, and real estate professionals, must comply with anti-money laundering and counter-terrorism financing (AML/CTF) requirements.

To support these professionals in preparing for compliance, AUSTRAC has released a sector-specific Starter Kit that offers a clear, step-by-step guide for developing an effective AML/CTF program. The following list highlights the key 4-step guide from the Starter Kit for the accounting and TCSP sector, designed to simplify your compliance process and ensure your practice is both protected and ready for the new regulatory landscape.

The 4-Step Guide to Compliance

The starter kit breaks your compliance journey into four distinct parts to help you build a solid foundation:

1. Risk Assessment: Identifying Your Vulnerabilities

You must maintain a current and accurate assessment of the money laundering and terrorism financing (ML/TF) risks your practice faces.

Service & Client Review: Evaluate which of your services are regulated and the types of clients you serve.
Risk Appetite: Decide what level of risk your practice is willing to accept. For instance, you might decide not to deal with clients involving high-value physical currency.
Country Risk: You must rate the risk level for each country you deal with by checking the databases like FATF high-risk jurisdictions, DFAT sanctions list and the Basel AML Index.

Resources: AUSRAC’s risk assessment

Pro Tip for Tranche 2 Entities:
Many tranche 2 practices underestimate how everyday services can be exploited for ML/TF. Start with AUSTRAC’s free sector-specific risk insights and indicators of suspicious activity (available for accountants, legal professionals, real estate, etc.) to quickly map your risk areas, and prioritise controls to demonstrate a proportionate, risk-based approach to AUSTRAC.

2. Personnel: Your First Line of Defence

Your staff are critical in preventing criminal exploitation.

Key Roles: You must identify all other AML/CTF-related roles and assign their duties, including AML/CTF compliance officer, senior manager and governing body as governance roles, and roles that have AML/CTF duties like CDD and SMR.
Personnel Due Diligence (PDD): You must conduct initial PDD before appointment and ongoing PDD to check the background, verify and monitor the suitability and integrity of your AML/CTF-related personnel.
Mandatory Training: All relevant staff must be trained to understand their specific obligations and how to apply your practice’s processes in their daily work.

Resources: AUSRAC’s Personnel forms , Policy document

Pro Tip for Tranche 2 Entities:
In smaller or busy professional practices, compliance often falls to already overloaded partners or managers. Appoint a dedicated AML/CTF compliance officer early (even part-time initially) and use online resources (such as AUSTRAC’s guidelines and materials, whitepapers and webinars) to upskill your team quickly.

3. Clients: Knowing Who You Are Dealing With

Customer Due Diligence (CDD) must be completed before you provide a professional service.

Identification & Verification: You must identify and verify the identity of all clients, including beneficial owners of companies and beneficiaries of trusts, etc. Capture and record all required specific data for each client type as outlined in the relevant CDD forms.
Screening: You are required to screen clients against Sanctions lists and access if they are Politically Exposed Persons (PEPs), high-risk or complex clients, to identify their ML/TF risks. Establish processes for handling offboarding and tipping-off obligations.
Ongoing Monitoring: You must conduct ongoing monitoring of client activity, enabling the detection of unusual or suspicious activities. Conduct periodic reviews every 1, 2, or 3 years for High, Medium, or Low risk clients respectively. You are also required to review and update your CDD forms, policies, and processes as necessary to ensure they remain aligned with changes in risk, regulations, or circumstances.

Resources: AUSRAC’s Policy document , Process document, Client forms

Pro Tip for Tranche 2 Entities:
Manually checking databases for every new client is a significant administrative task. AML/CTF digital solutions can automate this by instantly screening clients against the Financial Action Task Force (FATF), UN 1267, OFAC and global sanctions and watchlists during onboarding and ongoing checks, ensuring you never miss an updated listing.

4. Document & Approve: Making it Official

You must ensure the preparation, formal approval, and full implementation of your AML/CTF program, maintaining ongoing compliance with your obligations. This provides a reliable foundation for your staff and demonstrates your compliance to regulators.

Approval: Your customized AML/CTF program, including risk assessment, policy document, process document, and relevant forms, must be a written document and formally approved by a senior manager. Notify your governing body upon approval.
Implementation: You must ensure the approved AML/CTF program is fully implemented throughout your practice and manage any changes promptly.

Resources: AUSRAC’s Policy document

Pro Tip for Tranche 2 Entities:
Approval marks the start—real compliance happens through consistent implementation. Many tranche 2 practices make rollout smoother and more sustainable by adopting a centralised AML/CTF compliance platform early on. This brings all elements (risk assessment, policies, CDD records, screening, monitoring, reviews, and training logs) into one secure system, streamlines communication with task assignment, alerts, and collaboration features for staff and senior management, and provides a real-time dashboard for clear oversight of ML/TF risks, high-risk clients, pending reviews, open alerts, and overall compliance status—helping you embed the program into daily workflows, reduce oversights, and demonstrate active, effective management to AUSTRAC.

Using AML/CTF Solutions to Support AML/CTF Compliance

In today’s rapidly evolving money laundering landscape, traditional manual processes are inadequate for effective risk management. With the increasing emphasis on the use of technology, regulated Tranche 2 entities are encouraged to leverage appropriate digital solutions (often referred to as RegTech) to support the effective implementation and ongoing management of your AML/CTF program. These tools can enhance efficiency, accuracy, and scalability in meeting your compliance obligations under the AML/CTF regulatory requirements.

AML/CTF Solutions May Assist with Key Areas Such As:

Sanctions and PEP screening
Customer identification and verification
ML/TF risk rating and assessments
Ongoing customer due diligence and periodic reviews
Record-keeping, reporting and audit trails

Key Considerations When Selecting and Using Technology Solutions:

Database & Functionality
Comprehensive, reliable, up-to-date screening databases (sanctions, PEPs, adverse media) and features that meet your business needs with proven implementation success.
Australia Compliance and Expertise
Meets local AML/CFT regulations with demonstrated expertise and experience in compliance.
Security Standards
Robust security infrastructure and certifications to prevent data breaches.
Pricing Models
Transparent, predictable pricing models (per-search/ per-unique-search fees, subscriptions/ transaction basis) with clear additional costs.
Ongoing Support
Continuous maintenance, regulatory updates, user training, and dedicated account management.

SentroWeb® AML/CTF All-in-One Solutions to Meet Compliance Requirements

SentroWeb® AML/CTF RegTech solution is tailored for professional firms and Tranche 2 entities in Australia, enabling seamless and effective compliance with AUSRAC’s AML/CTF regulations.

Key Features:

✅ Trusted Dow Jones Database for comprehensive sanctions, PEPs, and adverse media screening
✅ Streamlined Customer Due Diligence (CDD) workflows to accelerate compliant onboarding
✅ Automated Ongoing Monitoring with alerts to stay ahead of emerging risks
✅ Comprehensive Records & Reports to ensure audit-ready documentation for smooth regulatory inspections
✅ Local Support with Free Monthly Training to keep your team updated
✅ Per-Unique-Search Pricing with flexible packages tailored to your business size.
✅ Top-tier Security with ISO 27001, 27017, and 27018 certifications to protect your data

Ingenique brings over 10 years of specialist AML/CTF expertise across the Asia-Pacific, serving as a trusted leader in compliance solutions for Designated Non-Financial Businesses and Professions (DNFBPs) like you. If you are unsure about the AML/CTF regulations, want to discuss your preparation steps, or need useful compliance tools, we are here to support you through this transition. Contact Ingenique today for a no-obligation consultation and demo.

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