AML/CTF Tranche 2 Toolkit
A working playbook for law firms, conveyancers, accountants, real estate agencies, trust and company service providers, and dealers in precious metals and stones that now fall inside Tranche 2.
The playbook is typically around 65 files in 13 numbered folders, with a README that maps every file. Excel workbooks are about 60 percent and PDF guides about 40 percent. Exact file names and the mix inside each folder vary with your role and situation.
The playbook is prepared by Gerard Blokdyk for your role and situation after you buy. Access is within 24 hours. The purchase is one time and carries a 30-day refund.
What you get
13 numbered folders and a README that maps every file, prepared for your role and situation. It is a playbook, not training, and it does not include a certificate.
Who it is for
For partners, compliance managers and MLROs in professional services firms that must enrol, assess risk, run CDD and report.
The 12 areas
Area 1. Scope and enrolment
- Check whether your service is a designated service under table 6
- Enrol on the Reporting Entities Roll now if you have not
- Record that the 29 July 2026 enrolment and compliance-officer notification date has passed
- Identify the sector exemptions that apply to your firm
Area 2. ML/TF risk assessment
- Assess ML/TF risk before the first designated service
- Review on triggers and at least every 3 years
- Document the methodology and conclusions
- Obtain senior manager approval
Area 3. AML/CTF program
- Write the policies, procedures, systems and controls
- Document the program before the first service
- Update within 14 days of a change
- Run an independent evaluation at least every 3 years
Area 4. Governance and compliance officer
- Designate a qualified and independent compliance officer
- Notify AUSTRAC of the officer
- Assess fitness and propriety
- Report to the governing body at least every 12 months
Area 5. Initial customer due diligence
- Complete initial CDD before the service
- Collect the minimum KYC for individuals, companies, trusts and government bodies
- Identify beneficial owners and the control structure
- Record the nature and purpose of the relationship
Area 6. PEPs, sanctions and high risk
- Screen politically exposed persons
- Record source of wealth and source of funds for PEPs
- Apply targeted financial sanctions
- Apply enhanced CDD for high risk and mandatory cases
Area 7. Simplified and delayed CDD
- Apply simplified CDD only for documented low risk
- Use delayed verification only within the limits
- Monitor pre-commencement customers
- Trigger full CDD when the conditions are met
Area 8. Reliance and third parties
- Use case-by-case reliance only where permitted
- Put the reliance agreement and access terms in place
- Assess the arrangement every 2 years
- Keep responsibility with your firm
Area 9. Monitoring and suspicious matters
- Monitor for unusual transactions and behaviour
- Report suspicious matters within 3 business days, or 24 hours for terrorism financing
- Do not tip off
- Keep the suspicion assessment record
Area 10. Threshold and cross-border reporting
- Report threshold transactions of $10,000 or more within 10 business days
- Report international value transfers within 10 business days
- Report cross-border movements of $10,000 or more
- Lodge the annual AML/CTF compliance report
Area 11. Records and audit
- Keep CDD records for 7 years after the relationship ends
- Keep program records for 7 years
- Keep transaction and reliance records
- Prepare for an AUSTRAC-required external audit
Area 12. Sector obligations
- Real estate: delayed CDD by the earlier of 28 days after exchange of contracts and 3 days before the initially agreed settlement date
- Lawyers and conveyancers: legal services and trust account rules
- Accountants, trust and company service providers: trusts and beneficial owners
- Dealers in precious metals and stones: CDD and threshold reporting
Dates that matter
- 1 July 2026: Tranche 2 obligations started.
- 29 July 2026: the enrolment and compliance-officer notification date for newly regulated Tranche 2 entities has passed. If your firm has not enrolled or notified, act now.
- 30 June 2027: the first annual compliance report period ends; lodge within 3 months.
How it works
The playbook is prepared by Gerard Blokdyk for your role and situation after you buy. Access is within 24 hours. The purchase is one time and carries a 30-day refund.