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Tranche 2 kickstart kit
A practical starter guide to getting your AML/CTF program sorted (without losing your mind).
From 1 July 2026, Tranche 2 businesses (hello, lawyers and real estate agents) need to have a working AML/CTF program in place before offering regulated services.
Our kickstart kit trims the fat and helps you move from “we know we have to do this” to “we’ve started and can prove it”.
⚠️ Based on AUSTRAC’s official guidance, this is a practical setup kit - not legal advice, just good advice.
Step 1: Nail the 4 non-negotiables
Before you do anything else, AUSTRAC wants four foundations in place. Without them, your AML/CTF program is just a fancy to-do list.
1. Risk – Know where you're exposed
You need a documented ML/TF risk assessment that reflects:
- The services you actually provide
- The types of clients you deal with
- How you deliver those services (in-person, remote, online)
- Whether you're dabbling internationally or in higher-risk areas
Your risk assessment drives everything: customer checks, when to escalate, what to monitor. Download AUSTRAC’S sector-specific risk assessment templates for your business:
2. People – Assign responsibility
You must clearly nominate:
- Your AML/CTF Compliance Officer
- A senior manager to approve the program
- Any frontline staff with AML/CTF duties
Each role must be documented, suitable, trained, and kept under review. Read more on AUSTRACS guidance to nominating an AML/CTF compliance officer.
Make the nomination official by filling out the relevant Personnel forms and sending through to AUSTRAC.
3. Clients – Onboarding and monitoring controls
You’ll need to show:
- How you do CDD (Customer Due Diligence)
- How you risk-rate your clients
- What enhanced checks look like for higher-risk clients
- What ongoing monitoring means during the relationship
- Where things escalate and how reports get filed
If you can’t explain how a client gets onboarded and monitored after, your program isn’t complete.
4. Documentation – If it’s not written down, it doesn’t exist
AUSTRAC expects:
- A written AML/CTF Program (policy + procedures)
- A completed risk assessment
- Records of decisions and approvals
- Approval from your senior manager
Verbal plans and vibes don’t count.
Download AUSTRAC’s policy and process documents to shape how you carry out steps 1.3 and 1.4 of the program starter kit:
Legal conveyancing policy document
Legal conveyancing process document
APLYiD is built for Tranche 2 compliance
Let’s be honest: Tranche 2 can feel difficult. It's time-sensitive, document-heavy, and can turn into unbillable work that someone still has to pay for if you don't have the right systems and processes in place. APLYiD makes compliance so smooth you'll hardly notice it:
✅ AML/CTF checks built into onboarding
✅ Real-time ID, PEP, sanctions, and risk checks
✅ Auto-generated, audit-ready records, with secure storage
✅ Less manual rework, fewer missed steps
You still own your risk. We just make it as easy as humanly possible.
APLYiD downloadable resources
We've made practical PDFs are designed to help you turn AUSTRAC’s guidance into clear, actionable steps inside your business, so you're not staring at a 100 page document wondering where to begin.
(All aligned with AUSTRAC’s guidance, ready for real-world use.)
