AML Compliance Checklist — Tranche 2 (2026)

Twelve steps from "am I captured?" to "independently reviewed". Pair with the cost calculator to budget each phase.

1. 01

   Confirm you provide a designated service

   Not every law/accounting/agency business is captured — only those providing table 6 designated services (client money handling, conveyancing, company formation, deposit taking). Check the AUSTRAC professional designated services list.

2. 02

   Enrol with AUSTRAC (free)

   New entities had a 29 July 2026 deadline. If you missed it, enrol now — late enrolment is far better than being caught unenrolled. AUSTRAC enrolment costs nothing.

3. 03

   Appoint an AML compliance officer

   Name the person responsible internally. Small firms often assign this to the principal.

4. 04

   Conduct a business risk assessment

   Document your ML/TF risks: customers, services, delivery channels, jurisdictions. Part A of your program depends on this.

5. 05

   Write your Part A AML/CTF program

   Risk-based systems and controls. Templates from AUSTRAC, software vendors, or a consultant (see the cost calculator).

6. 06

   Write your Part B program (customer identification)

   Procedures for identifying customers and beneficial owners, and ongoing monitoring. The heart of CDD.

7. 07

   Implement KYC / ID verification

   Manual or software-based. Software from ~$59/month per vendor claims; pay-per-check options suit low volumes.

8. 08

   Train your staff

   Everyone involved in designated services. Records required — free AUSTRAC e-learning courses count.

9. 09

   Set up reporting processes

   SMRs (suspicious matter reports — within 24 hours of suspicion) and ITRs (international funds transfer instructions). Know your AUSTRAC Online access.

10. 10

    Record-keeping

    Transaction and identity records, retained 7 years (5 for some).

11. 11

    Schedule your independent review

    Part A programs require periodic independent review. Budget it — see the calculator line item.

12. 12

    Diary the transitional deadlines

    AUSTRAC transitional rules phase obligations; first extensions possible from 1 July 2029. Track AUSTRAC updates.

Planning guidance only — obligations are set by the AML/CTF Act 2006 and AUSTRAC guidance at austrac.gov.au.