AML/CTF obligations for Tranche 2 businesses have been in force since 1 July 2026.

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In force since 1 July 2026

AML/CTF compliance for Australian Tranche 2 businesses

Real estate agencies, buyers agents and developers, conveyancers and settlement agents, law firms, accounting practices, and trust and company service providers.

One platform for the whole obligation, not just the identity check. Customer due diligence, beneficial ownership, screening, risk, reliance, program documents and an 8-year audit trail. Compliance status syncs to REX without replacing the systems you already run.

Identity verification with biometric liveness
Beneficial ownership, companies and corporate trustees
Sanctions, PEP and adverse media screening
Risk scoring with recorded reasoning
CDD reliance register, sections 37A and 38
Program documents as one linked set
Staff training with completion records
8-year tamper evident audit trail
Integrates withREX CRM
Switching from another provider

Already using something else?


Most tools sold into Tranche 2 are identity verification with AML branding. They verify an individual and stop. That holds up until a company buys the property, or AUSTRAC asks to see your program. Six things worth checking your current tool actually does.

01

Resolve a company to the people behind it

One request returns the natural persons who own or control the entity, each with screening status, plus a bureau report attached as evidence. Your compliance officer approves the determination before CDD proceeds.

Without it: you read an ASIC extract yourself and hope you traced the chain correctly.

02

Produce your AML/CTF program documents

The business wide ML/TF risk assessment, the AML/CTF policies, the compliance action plan and the staff training manual, generated from the same answers so they stay consistent with each other.

Without it: you bought a screening tool and you still have no program.

03

Handle CDD reliance under sections 37A and 38

A statutory reliance register and secure evidence sharing, so a party verified once by another reporting entity is not put through the whole process again.

Without it: the same buyer is verified by the agent, then the conveyancer, then the lawyer, and someone pays three times.

04

Train everyone who touches a designated service

Sales agents, property managers and admin staff, not only the compliance officer. Role appropriate, available in multiple languages, with completion records a supervisor can inspect.

Without it: your program says your staff are trained and nothing proves it.

05

Record why, not just what

Every risk score and re-score, every officer override with its written reason, every match disposition. Immutable, timestamped, kept for seven years.

Without it: a spreadsheet export, and a decision you have to reconstruct from memory months later.

06

Let your clients pay for their own checks

Buyers and sellers pay through a secure link, the same way they pay for a conveyancing search. Every customer paid check earns credit back against your subscription.

Without it: compliance stays a cost line that grows with your transaction volume.

If your current tool handles the first item on that list, it is probably serving you well. If it does not, the gap turns up on the transaction where it costs the most.

See the difference in 20 minutes
Your obligation, your liability

You cannot outsource your AML obligations

If your business provides a designated service, your business is the reporting entity. Not your consultant. Not your outsourced provider. You.

AUSTRAC is explicit on this. Outsourcing an AML/CTF function does not move the liability. Your business remains legally responsible for a breach, and your business carries the penalty.

AML Guard is built around that reality. Every screen states what your team needs to do, why it matters and what happens next. Plain English guidance, step by step workflows, and notifications that link straight to the action required. Your team stays in control, and your audit trail proves it.

Read more on outsourcing and liability

Maximum civil penalty, individual$6.6m
Maximum civil penalty, body corporate$33m

As at 2026. Source: AUSTRAC, "Using outsourcing to help meet your AML/CTF obligations".

Built for the way you already work

Compliance that stays out of the way


Your obligation runs alongside a transaction that still has to settle. AML Guard fits the work rather than interrupting it.

Fits your workflow

Compliance status syncs to REX so your team sees progress against a listing. Only status indicators leave the platform, never sensitive CDD data.

Cost recovery built in

Buyers and sellers pay for their own checks through a secure link. Completed checks earn credit back against your subscription, capped at your licence fee.

Audit ready, always

Every check, decision and status change is logged and cannot be edited or deleted. Encrypted vault, 8-year retention, ready the day AUSTRAC asks.

Where most tools stop

Beneficial ownership, traced and evidenced


When your customer is a company, the obligation is to identify the natural persons who ultimately own or control it. One request returns them, each with screening status, plus a downloadable bureau report as evidence. Where a trust or SMSF holds through a corporate trustee, that trustee runs its own determination on its ACN.

  • Single authoritative bureau determination
  • Owners resolved with screening status
  • Corporate trustees of trusts and SMSFs
  • Officer approves before CDD proceeds
  • One click party creation per owner
  • Fixed price, no per lookup spend
The whole obligation

What the platform covers


From enrolment onwards, in one place, with the evidence recorded as you go.

Identity verification

Clients verify on their phone with a biometric face match and document scan. 14 document types accepted. Results flow straight into the compliance case.

Sanctions and PEP screening

Over 200 country watchlists including DFAT, UN, EU and OFAC, plus adverse media and deceased checks, with automatic re-screening.

CDD and reliance

Guided workflow through verification, screening, risk and sign off. Statutory reliance register under sections 37A and 38, with secure evidence sharing.

Risk scoring and monitoring

A 42 factor engine across six AUSTRAC aligned categories. Ratings re-score when new information lands, and an officer override always carries a written reason.

Program documents

Guided wizards produce the four artefacts as one linked set: the ML/TF risk assessment, the AML/CTF policies, the compliance action plan and the training manual.

8-year audit trail

Every check, decision and status change logged and immutable. Encrypted vault with time limited access links. When AUSTRAC asks, the evidence is assembled.

REX CRM integration

Compliance status pushes to REX with no sensitive data leaving the platform. Link cases to contacts and listings, and pre-check your database before you call.

Staff training portal

Role appropriate modules in multiple languages, with completion records held against each staff member for inspection.

SMR and TTR reporting

Suspicious matter and threshold transaction report preparation, with tipping off controls built in and an officer approval step.

Client intake portal

Your branded secure link. The client enters details, declarations and source of funds, pays and verifies identity in one flow, then your agents and officer are alerted.

Pricing

Your clients pay for their checks. You keep the credit.


A three user agency needs four customer paid verifications a month to offset the subscription entirely.

Platform subscription
$75 per user, per month
Plus GST, $82.50 total
Three user bundle $170 per month plus GST, $187.00 total
  • Identity verification
  • Sanctions and PEP screening
  • Risk scoring engine
  • CDD reliance register
  • Beneficial ownership tracing
  • Client intake portal
  • Program document wizards
  • Staff training portal
  • SMR and TTR reporting
  • 8-year audit trail
  • REX status push
  • Staff and agent alerts
CDD check pricing
Standard individual$45 plus GST$49.50 total
Higher risk individual$60 plus GST$66.00 total
Companyfrom $90 plus GST$99.00 total

Every check includes identity verification, sanctions and PEP screening, adverse media, deceased check and risk assessment. The total shown is what a buyer or seller pays on the secure link.

How credit back works. Buyers and sellers receive a secure payment link and pay for their own checks, the same way they pay for a conveyancing search. Every customer paid check earns 100% credit back against your subscription, capped at your licence fee. Credit is applied to the GST exclusive subscription amount.
Tranche 2

What the obligation actually requires


Who does Tranche 2 apply to?
Australia's AML/CTF reforms extended obligations to real estate professionals, conveyancers, lawyers, accountants, and trust and company service providers. Those obligations commenced on 1 July 2026 and are in force now. If your business provides a designated service, it is a reporting entity.
What do I have to have in place?
Enrolment with AUSTRAC, an AML/CTF program made up of a business wide ML/TF risk assessment and AML/CTF policies, an appointed compliance officer, customer due diligence before you provide a designated service, beneficial ownership identification for entities, risk assessment, sanctions and PEP screening, staff training, 8-year record keeping, suspicious matter and threshold transaction reporting, and independent evaluation.
My program still uses the old Part A and Part B structure. Is that a problem?
The 2024 amendments replaced the Part A and Part B split with a single program built from the risk assessment and the policies. An existing program does not have to be rewritten overnight, but new content should be drafted against the current structure so the transition is straightforward when you next revise it.
What is beneficial ownership and why does it matter?
Where your customer is a company, trust or other entity, you must identify the natural persons who ultimately own or control it, rather than accepting the entity at face value. For a company, AML Guard establishes this through a single authoritative bureau determination that returns the resolved owners with screening status and a downloadable report as evidence. Where a trust or SMSF holds through a corporate trustee, that trustee runs its own determination.
Can I rely on another party's CDD?
Yes. The AML/CTF Act allows formal reliance arrangements under sections 37A and 38, so an agent can rely on verification completed by another reporting entity such as a conveyancer. AML Guard includes a statutory reliance register and secure evidence sharing between parties.
Do I need source of funds on every transaction?
No. Source of funds sits in the enhanced due diligence layer, applying to higher risk customers, unusual transactions or politically exposed persons. Standard CDD covers identity verification, screening and risk assessment.
I already have a provider. What happens to my existing records?
Your existing compliance records remain your evidence and stay subject to your seven year retention obligation. AML Guard takes over from your next designated service, so there is no migration project to run before you can start.
Does AML Guard integrate with REX?
Yes. Compliance status pushes to REX with no sensitive data leaving the platform. Cases link to REX contacts and listings, and you can pre-check your database before you call.

See it against what you have now

Twenty minutes. We walk a complete CDD case end to end, run a live beneficial ownership determination, and show you the credit back model against your actual transaction volume.

Book a demo

No commitment. AML Guard is not self service, so every account is configured to your designated services and risk profile before you use it.