Check your firm's Tranche 2 readiness
Answer 9 quick questions to get a readiness score and an action plan for your firm. It takes under 2 minutes.
What industry is your firm in?
Tranche 2 of the AML/CTF Act extends obligations to accounting firms, real estate agencies and other professional services.
Eight questions for your AML setup.
Use this checklist on your current platform, or your current spreadsheet stack. AUSTRAC won't grade you on effort. They'll grade you on evidence.
-
Can it produce AUSTRAC's SMR 3.0 XML file exactly?
Or do staff re-key every field into AUSTRAC Online under deadline?
-
Does it isolate SMR records so only the AMLCO can see them?
Tipping off is a criminal offence under s 123. Every record staff can see is a risk.
-
Does it generate tamper-evident, hashed evidence packs on demand?
A hashed pack shows the record has not changed since it was produced. A screenshot does not.
-
Can it manage reliance arrangements end-to-end?
The s 37 and s 38 distinction, the agreement PDF, its lifecycle and AMLCO sign-off.
-
Does it identify ultimate beneficial owners (UBOs) and flag risky ownership structures?
Owners of 25% or more, control relationships and structure risk flags.
-
Does it draft ownership structures from trust deeds and ASIC extracts?
Check what is live versus promised, and whether you would still type every field by hand.
-
Does it track every obligation in one calendar?
Reviews, training, AMLCO appointments, retention anchors.
-
Does it apply country risk from Basel, FATF, and DFAT?
The list should be re-indexed when the source indexes update.
If your current setup can't answer yes to each question,
duely does each of these.