Compliance deadline: 1 July 2026

AUSTRAC Tranche 2 is here.
Your AML/CTF program, generated in minutes.

If you're an accountant, lawyer, real estate agent, precious metals dealer, or trust and company service provider — you're now a reporting entity under AUSTRAC. 5,534 obligations across 768 rules. AuditDSS generates your complete AML/CTF compliance program and scores your existing policies against every obligation. No LLM wrapper. Every clause traced to the source obligation.

5,534

AML/CTF obligations

768

Rules across both instruments

70,000+

New reporting entities

1 Jul 2026

Full compliance expected

Are you a new reporting entity?

The AML/CTF Rules 2025 extend AUSTRAC's regime to these sectors for the first time. If you provide any of these designated services, you must comply.

Accountants

  • Tax agent services involving company/trust structures
  • SMSF administration and auditing
  • Business advisory involving equity or debt financing
  • Company formation and restructuring

Lawyers

  • Conveyancing and property transactions
  • Company/trust establishment and restructuring
  • Equity or debt financing arrangements
  • Acting as nominee director or trustee

Real Estate Agents

  • Brokering sale or purchase of real estate
  • Property management involving trust accounts
  • Commercial property transactions
  • Property development sales

Precious Metals Dealers

  • Buying or selling precious metals or stones
  • Bullion dealing and trading
  • Jewellery involving high-value precious metals
  • Precious metals storage and custody

Trust & Company Service Providers

  • Forming companies or trusts for clients
  • Acting as registered agent or office
  • Providing nominee directors or secretaries
  • Selling shelf companies

Wealth Advisers

  • Financial planning involving managed investments
  • Superannuation advice and SMSF setup
  • Estate planning with trust structures
  • Portfolio management and investment advisory

If you answered yes to any of the above, you are regulated by AUSTRAC and must have a compliant AML/CTF program by 1 July 2026.

What AUSTRAC requires — decomposed into testable obligations

Most guides tell you "get an AML/CTF program." We show you exactly what that means — 5,534 individual obligations, each one testable.

AML/CTF Program

Critical

Establish and maintain a compliant AML/CTF program, including a Part A (general) and Part B (customer identification) component.

Customer Due Diligence

Critical

Initial, ongoing, and enhanced CDD. Verify identity before providing designated services. Update when triggers occur.

Transaction Monitoring

High

Monitor transactions for suspicious activity. Implement automated or manual systems proportionate to risk.

Suspicious Matter Reporting

Critical

Report suspicious matters to AUSTRAC within prescribed timeframes. Document the basis for suspicion.

Record Keeping

High

Retain CDD records, transaction records, and AML/CTF program documentation for 7 years.

Risk Assessments

High

Conduct ML/TF risk assessments covering customers, services, delivery channels, and jurisdictions.

Employee Training

Medium

Train employees to identify suspicious activity, understand obligations, and follow AML/CTF procedures.

AUSTRAC Registration

Critical

Register with AUSTRAC as a reporting entity before providing designated services.

Full AUSTRAC AML/CTF coverage — both instruments

AuditDSS covers both the new 2025 Rules (Tranche 2) and the existing 2007 Rules. Both fully decomposed into testable obligations with enforcement-calibrated risk scoring.

Why both instruments matter: AUSTRAC's 23 enforcement actions (totalling $2.69B in penalties) were all under the 2007 Rules. That enforcement history calibrates the risk scores for both instruments. New Tranche 2 entities get enforcement-informed risk scoring from day one — the closest proxy for where AUSTRAC will focus.

From zero to compliant — in minutes, not months

Other providers give you templates. AuditDSS generates regulation-mapped compliance programs and scores your documents against every obligation.

1

Generate

Answer a short questionnaire about your business. AuditDSS generates your complete AML/CTF program — L2 policy, L3 procedures, L4 forms — mapped to every AUSTRAC obligation that applies to you.

2

Assess

Upload your existing policies and internal documents. AuditDSS scores them against every obligation in the AUSTRAC Rules — gaps identified, risk-ranked, cited to the source.

3

Remediate

Get a prioritised remediation roadmap. Every gap ranked by severity, likelihood, detectability, and enforcement history. Fix the high-risk gaps first.

4

Evidence

Store CDD records, transaction logs, training completion, and SMR documentation in the evidence vault — mapped to the specific obligations they satisfy.

Everything you need for AUSTRAC compliance

Compliance Program Builder

Generate your complete AML/CTF program — L2 policy, L3 procedures, L4 forms and checklists — mapped to every AUSTRAC obligation. Ready in minutes.

Gap Analysis

Upload your existing policies and score them against every obligation in the AUSTRAC Rules. See exactly where you are compliant and where you have gaps.

Risk Scoring

4-axis probabilistic scoring — severity, likelihood, detectability, and regulatory focus — calibrated on 23 AUSTRAC enforcement actions.

Obligation Mapping

Every clause in your AML/CTF program traces back to a specific AUSTRAC obligation. No guesswork. No hallucinated compliance.

Remediation Tracking

Track every gap from identification through to closure. Assign owners, set deadlines, and generate evidence of remediation.

Not an LLM wrapper. Not a template.

Most "AI compliance" tools paste your business name into a generic template or feed a regulation to ChatGPT and call it a compliance program. That's not compliance — that's a liability.

AuditDSS is different:

  • Deterministic obligation decomposition — every regulation is decomposed into individual, testable obligations by compliance engineers, not generated by AI
  • Every clause traces to a source obligation — your AML/CTF policy doesn't just say "conduct CDD." It maps each CDD requirement to the specific AUSTRAC obligation it satisfies
  • Enforcement-calibrated risk scoring — risk scores are informed by AUSTRAC's 23 enforcement actions and 133 FATF mutual evaluation assessments, not arbitrary red/amber/green
  • Dependency graph — obligations don't exist in isolation. AuditDSS models how they connect, so fixing one gap can cascade compliance improvements across related obligations

AUSTRAC's enforcement track record

New Tranche 2 entities have no direct enforcement precedent. But AUSTRAC's enforcement of the 2007 Rules tells you exactly where the regulator focuses.

$2.69B

Total penalties imposed

23

Enforcement actions

133

FATF assessments informing scores

AUSTRAC has not signalled a lenient approach to Tranche 2. The regulator's track record — including CBA's $1.3B penalty, Westpac's $1.3B penalty, and Crown's $450M penalty — demonstrates willingness to impose severe consequences. New reporting entities should expect the same enforcement rigour applied to financial institutions.

Key dates

31 March 2026

Rules take effect

The AML/CTF Rules 2025 commence. Obligations are enforceable from this date.

Now — June 2026 YOU ARE HERE

Prepare your program

Register with AUSTRAC. Build your AML/CTF program. Train your staff. Implement CDD procedures.

1 July 2026

Full compliance expected

AUSTRAC expects full compliance. Transition period for good-faith efforts, but obligations are enforceable.

Further reading

Don't wait until AUSTRAC comes knocking

Generate your AML/CTF program in minutes. Score your existing policies against every obligation. Know exactly where you stand before the deadline.