Free Tranche 2 Readiness Checklist

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1 Understand your obligations

Confirm whether your firm provides designated services and is a reporting entity from 1 July 2026

Identify which specific designated services you provide

Enrol or confirm enrolment with AUSTRAC by the required date

Nominate an AML/CTF compliance officer

Brief owners and senior managers on their accountability for the program

2 Complete your risk assessment

Assess money laundering and terrorism financing risk across your customers

Assess risk across the services, channels and jurisdictions you deal with

Document the methodology used to rate customer risk

Define what makes a customer low, medium or high risk

Set a schedule to review and update the risk assessment

3 Build your AML/CTF policies and governance

Document AML/CTF policies, procedures and controls

Define roles and responsibilities across the compliance function

Set role-based access so staff see only what their role requires

Establish an approval and sign off process for higher risk customers

Plan and schedule staff AML/CTF training

4 Set up customer due diligence and onboarding

Define the identity information you must collect for each customer type

Set a process to identify and verify beneficial owners

Establish enhanced due diligence steps for higher risk customers

Capture source of funds or wealth where the risk requires it

Standardise a client acceptance and record creation workflow

5 Screening and ongoing monitoring

Screen customers against the DFAT list, UN, OFAC, EU and UK HMT

Screen customers against domestic, foreign and international PEP databases

Set a process to review and clear potential screening matches

Schedule periodic re-screening of existing customers

Define trigger events that prompt a fresh review

6 Reporting, records and audit readiness

Establish a process to prepare and lodge suspicious matter reports

Confirm any threshold transaction reporting that applies to you

Set record retention for at least seven-years

Keep a tamper-evident trail of decisions and screening outcomes

Run a mock audit to confirm records can be produced on request

You have worked through every checkpoint.

A checklist is a starting point, not a substitute for a documented program. Talk to the AccSource compliance team to turn this into an operating AML/CTF program in ClearTrace.

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This checklist is general guidance to help plan for Tranche 2 and does not constitute legal or regulatory advice. Confirm your obligations against current AUSTRAC guidance and, where needed, a qualified AML/CTF specialist.

Is Your Firm Tranche 2 Ready?