AML Compliance Guide

AML/CTF compliance platform for Australian Tranche 2 entities

Free program builder, risk assessment, CDD and registers for accountants, lawyers, conveyancers, real estate agents, TCSPs and precious-metals dealers who must be compliant under AUSTRAC Tranche 2 by 1 July 2026.

Note: Pricing and features for other vendors below are sourced from each vendor's public website and checked on the "last updated" date. Confirm current plans directly with the vendor before buying. This is general guidance, not legal advice.

Last updated: 2 July 2026 · Written against AUSTRAC's published Tranche 2 guidance and the AML/CTF Act 2006 (Cth)

  • Free core toolkit — no card required
  • Mapped to AUSTRAC's 6 minimum program components
  • Records retained for the AUSTRAC-required 7 years
  • No vendor lock-in — export your data anytime

AML/CTF Tranche 2 obligations commenced 1 July 2026. AUSTRAC enrolment for newly regulated accountants, lawyers, conveyancers, real estate agents and similar professions closes 29 July 2026. If you haven't picked a way to build and run your program yet, here's what's actually on the market — compared on price and features.

Are you a reporting entity?

AML/CTF obligations are triggered by providing a specific "designated service" listed in Schedule 1 of the AML/CTF Act — not by your industry alone. These are the Tranche 2 sectors and the services that typically trigger obligations:

Sector Typical designated service
Real estate professionals Facilitating the sale or purchase of real property (agents, buyer's agents, some developers)
Lawyers and conveyancers Managing client money, property or businesses; acting on the sale/purchase/transfer of real property or business assets
Accountants and bookkeepers Managing client money or assets; acting as a formation agent; certain trust and company services provided alongside accounting
Trust and company service providers Forming companies, acting as company secretary, providing a registered office, arranging for a person to act as a director, trustee or nominee shareholder
Dealers in precious metals, stones and products Buying or selling precious metals, stones or products above the AUSTRAC-set threshold
Virtual asset service providers Exchanging, transferring or safekeeping virtual assets on behalf of a customer
Financial advisers Certain financial product advice and arrangement services captured under Schedule 1

Not exhaustive — read the full AUSTRAC Tranche 2 guidance or the Act itself to confirm whether a specific service you provide is captured.

Sector paths

Each profession page covers the obligations, deadlines and designated services specific to that sector:

Motor dealers and general high-value-goods dealers aren't yet a dedicated sector page on this site — see the follow-up report for that gap.

What is an AML/CTF compliance platform?

Software that helps a reporting entity build, run and evidence its anti-money laundering and counter-terrorism financing program, instead of assembling it from scratch across Word documents, spreadsheets and AUSTRAC PDFs. It typically covers risk assessment, customer due diligence, governance and training registers, and reporting decisions — the components AUSTRAC expects every program to address.

The market roughly splits into two groups: heavier platforms built for banks, remitters and casinos under Tranche 1, with automated transaction monitoring and enterprise-scale pricing; and lighter platforms built specifically for Tranche 2 professional services businesses, sized for a proportionate, documented manual process. Picking the wrong category is a common — and expensive — mistake.

AML/CTF compliance platforms compared

Ordered roughly cheapest to most expensive (or least to most disclosed, where a vendor doesn't publish pricing):

AML Compliance Guide

This platform
Built for
Tranche 2 professionals — accountants, lawyers, conveyancers, real estate agents and similar
Pricing
Free core toolkit (program builder, risk assessment, registers) with a free account
Notable strength
Program builder mapped to AUSTRAC's 6 minimum components, live customer risk scoring, and governance, training and SMR registers in one place
Watch out for
No automated transaction monitoring — by design, since AUSTRAC does not require it for a proportionate Tranche 2 program
Built for
Real estate and property professionals specifically
Pricing
From $59/month
Notable strength
Built narrowly for the property sector rather than professional services generally
Watch out for
Not built for accountants, lawyers or conveyancers working outside property transactions
Built for
6 Tranche 2 categories, aimed at businesses under 20 staff
Pricing
$73.37/month (incl. GST), no lock-in contract
Notable strength
Fixed low monthly fee, with EDD workflow and beneficial ownership tracing included
Watch out for
Identity verification checks are billed separately at $4 each on top of the monthly fee
Built for
Accountants, lawyers, conveyancers and real estate agents
Pricing
$8 per identity + screening check (usage-based)
Notable strength
AML/CTF Program Generator plus automated KYB for trusts and SMSFs
Watch out for
No flat published subscription — cost scales with how many checks you run
Built for
Real estate, conveyancers, legal practitioners and accountants
Pricing
Advertised free until 1 July 2026 — that date has now passed, so confirm current pricing
Notable strength
Risk assessment and staff training were bundled into its free introductory period
Watch out for
Ongoing pricing after the promotional period isn't published — check their calculator before committing
Built for
Real estate agents, conveyancers, auctioneers and lawyers who hold client funds in trust
Pricing
$1,200–$2,400/year depending on user and ID-check limits
Notable strength
Bundles AML/CTF with trust accounting and integrates with Xero, MYOB and QuickBooks
Watch out for
AML/CTF plans are priced separately from, and in addition to, its trust accounting plans
Built for
All AUSTRAC reporting entities, not just Tranche 2
Pricing
From around $350/month
Notable strength
Automated SMR/TTR/IFTI/ACR reporting, transaction monitoring and AI document verification
Watch out for
Built for the full range of reporting entities — more automation and cost than most Tranche 2 practices need
Built for
Legal, accounting, conveyancing, real estate and precious metals sectors
Pricing
Not published — request a quote
Notable strength
Dedicated customer-facing portal for CDD intake, kept separate from the internal review workspace
Watch out for
No public pricing to compare against other options up front

AUSTRAC obligation → platform feature

What each core Tranche 2 obligation actually requires, and the specific free-toolkit feature that covers it:

What to look for, whichever you pick

Check any platform above — or any other one you're evaluating — against these before you commit:

Maps to AUSTRAC's minimum program components

Direct coverage of the 6 components AUSTRAC requires — governance, risk assessment, ongoing CDD, third-party reliance, personnel due diligence and training, and independent evaluation — not a generic global AML checklist.

AUSTRAC guidance

Proportionate to your risk profile

Tranche 2 businesses aren't required to run automated transaction-monitoring software. A platform built for this sector should support a documented, consistently applied manual process instead.

AUSTRAC guidance

A real CDD workflow

Can it run and record initial CDD, apply enhanced due diligence for higher-risk customers, and prompt a review when a customer's risk profile changes?

AUSTRAC guidance

Governance and personnel registers

Compliance officer appointment and eligibility, staff due diligence, and training completion — the records AUSTRAC expects a business to produce on request.

Documented reporting decisions

A program needs to show the reasoning behind suspicious matter reporting decisions, including cases where a report was considered but not filed.

Independent evaluation readiness

AUSTRAC requires an independent evaluation at least once every 3 years. Records need to be exportable or reviewable by someone outside your compliance function.

Built for your tier, not a different one

Software built for banks, remitters and casinos (Tranche 1) is a different product to one built for newly regulated professions (Tranche 2).

Transparent, checkable pricing

Some platforms publish a flat monthly fee, others charge per identity check, others don't publish pricing at all. Get the real number before you compare features.

What AML Compliance Guide actually looks like

Not mockups — these are live screens from the free toolkit, no account required to try them.

Live customer ML/TF risk rating tool scoring a real estate agent as Low Risk with a running total score

Customer risk rating scores live as you answer — this example shows a real estate agent scoring across Initial CDD, updating the risk band and required CDD action (Standard, Enhanced) in real time, with a section-by-section score breakdown on the right.

AML/CTF program builder showing a 6-step progress tracker with autosaved answers

Program builder tracks progress across all 6 AUSTRAC minimum components and autosaves in the browser as you go — you can start answering before creating an account, then save your plan permanently when you're ready.

SMR decision log form with fields for date, description of the suspicious matter, and documented reasoning

SMR decision log — every assessment gets a timestamped entry, whether or not you end up filing. This is what makes a "we considered it and decided not to report" decision defensible under audit, instead of just a memory.

Pricing

One real, public tier — see the comparison table above for how competitors' pricing (where published) stacks up.

Free

Program builder, risk assessment, compliance officer / staff due diligence / training / SMR registers, enrolment preparation, guidance library — all included with a free account. No card required, no seat limits published.

Identity verification within the CDD tool is a paid, per-check step (pricing shown at the point of use) — everything else on this list is free.

Everything in the free toolkit

Who it's for

Built for the professions newly covered by AML/CTF Tranche 2, including:

How it works

1

Answer questions about your business

The program builder asks about your services, customers and delivery channels to work out which obligations apply to you.

2

Get your 7-step program plan

A draft AML/CTF program mapped to the 6 AUSTRAC minimum components, ready to refine and approve.

3

Run risk assessments and CDD checks

Rate customer risk and record due diligence as you onboard, using the same account.

4

Keep your registers current

Compliance officer, staff due diligence, training and SMR decision registers stay in one place, ready for an audit or independent evaluation.

Frequently asked questions

Do I need to enrol with AUSTRAC?

If your business provides a "designated service" listed in Schedule 1 of the AML/CTF Act — for example, certain legal, conveyancing, accounting, real estate, trust and company, or precious metals/stones services — you must enrol with AUSTRAC before providing that service. Enrolment for newly regulated Tranche 2 entities closes 29 July 2026. See the <a href="#reporting-entity" class="text-blue-600 hover:underline">designated services table above</a> to check your sector.

What is a "designated service"?

A designated service is a specific service listed in Schedule 1 of the AML/CTF Act 2006 (Cth) — not every service your business provides. For a lawyer, it might be managing client money in a transaction; for a real estate agent, it's facilitating the sale or purchase of real property. Providing a designated service is what triggers AML/CTF obligations, not your job title or industry alone.

What's the difference between Part A and Part B of an AML/CTF program?

Under the amended program framework, Part A is the risk-based core of your program — your ML/TF risk assessment and the policies, procedures and controls that respond to it (governance, CDD, training, independent evaluation). Part B covers the customer identification procedures used to verify who your customers are. Existing reporting entities had to move to this Part A/Part B structure by 31 March 2026; new Tranche 2 entities build to it from the start. See our <a href="/aml-ctf-program-requirements" class="text-blue-600 hover:underline">program requirements guide</a> for the full breakdown.

When do Tranche 2 obligations start?

AML/CTF Tranche 2 obligations commenced on 1 July 2026. AUSTRAC enrolment for newly regulated entities — accountants, lawyers, conveyancers, real estate agents, TCSPs, and dealers in precious metals and stones — closes 29 July 2026.

Who is my AML/CTF Compliance Officer, and who's eligible?

Your compliance officer must be at management level, ordinarily resident in Australia (if you operate through a permanent establishment here), and a fit and proper person — they don't need to be an employee or hold direct reports, but they do need real authority over the program. You must appoint one within 28 days of providing a designated service and notify AUSTRAC within 14 days of appointment. See our <a href="/compliance-officer-requirements" class="text-blue-600 hover:underline">compliance officer requirements guide</a>.

Do accountants need to lodge suspicious matter reports (SMRs)?

Yes — any reporting entity, including accountants providing a designated service, must submit an SMR to AUSTRAC as soon as practicable after forming a reasonable suspicion, regardless of whether a transaction proceeds. Decisions not to file also need to be documented and reasoned; an undocumented "we considered it and decided not to report" is hard to defend under audit.

What triggers enhanced customer due diligence (ECDD)?

Common triggers include a customer or transaction being assessed as high ML/TF risk, a politically exposed person (PEP), instructions inconsistent with the customer's known profile or stated purpose, unusual transaction patterns, adverse media, or a connection to a high-risk jurisdiction. Your program needs to document what ECDD measures apply — extra identity evidence, senior sign-off, more frequent review — and when they're triggered.

How is source of funds verified for a Tranche 2 transaction?

There's no single prescribed method — AUSTRAC expects a risk-based approach. For lower-risk customers this might be a client's own statement of the funds' origin corroborated by supporting documents (payslips, sale contracts, loan approvals); for higher-risk customers you'd expect independent verification such as bank statements tracing the funds, or a solicitor's letter. The higher the risk rating, the more corroboration is expected.

Do Tranche 2 businesses need automated transaction-monitoring software?

No. AUSTRAC's guidance for Tranche 2 entities accepts a proportionate manual process — for example, reviewing client instructions against their known profile — provided it is consistently applied and documented. Platforms like OverSEER AML that build in automated transaction monitoring are aimed more at Tranche 1 entities (banks, remitters, casinos) than a typical accounting or conveyancing practice.

Is a free platform enough for Tranche 2 compliance?

For a straightforward, proportionate program, a free toolkit that maps to AUSTRAC's minimum components can be enough to get a working program in place. More complex or higher-risk businesses may still need tailored advice from a consultant or lawyer, or a paid platform with built-in identity verification at scale.

What are the best AML/CTF compliance platforms for Tranche 2 businesses in Australia?

There's no single "best" platform — it depends on your sector and budget. AMLTranche and Flagship AML are the cheapest fixed-fee options (from $59–$73/month), ClearAML and TrustSoft bundle in identity/KYB checks or trust accounting, OverSEER AML is built for the full range of reporting entities including banks and remitters (and priced accordingly, from around $350/month), and AML Compliance Guide's core toolkit — program builder, risk assessment and registers — is free.

How does AML Compliance Guide compare to paid platforms like ClearAML or Flagship AML?

Paid platforms typically bundle identity verification and sanctions screening into their pricing, charged either as a flat monthly fee (Flagship AML, TrustSoft) or per check (ClearAML). AML Compliance Guide focuses on the program, risk assessment and register side of Tranche 2 compliance — the parts every reporting entity needs regardless of transaction volume — and keeps that free, with a paid identity verification step inside the CDD tool.

Try the free toolkit for yourself

Use our free 15-minute compliance tool to build your 7-step AML/CTF Tranche 2 plan — no consultant needed.

Start Free Compliance Tool →

Not sure you're covered yet?

Check the AML/CTF program requirements to see what a compliant program must contain.

View program requirements →

Written from AUSTRAC's published Tranche 2 guidance and each vendor's public website. Not legal advice — complex or high-risk businesses should seek professional advice for their specific situation.