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Sumit Arora

Full-Stack Architect

Brisbane, Australia
January 18, 2026
Compliance Guide15 min read

AML/CTF Compliance Workflow for Tranche 2 Entities

A conceptual workflow mapping the typical Customer Due Diligence (CDD) process for Tranche 2 entities (lawyers, accountants, real estate professionals, conveyancers) under the AML/CTF Act 2006 and AML/CTF Rules 2025.

Important Disclaimer

This workflow is a conceptual representation developed through technical study of the AML/CTF legislation and rules. It is for educational and illustrative purposes only and does not constitute legal advice. For authoritative guidance, please consult AUSTRAC directly or seek qualified legal advice. If you have feedback or corrections, please contact sumit@getpostlabs.io.

1 July 2026
Tranche 2 obligations commence
31 March 2026
AUSTRAC enrolment opens

Interactive Compliance Workflow

Click on any step to see detailed explanation, legal references, and requirements.

Phase 1
Customer Onboarding
Collect customer information and determine CDD pathway
Phase 2
Verification & Screening
Verify identity and screen against PEP/sanctions lists
Phase 3
Risk Assessment & Approval
Assess ML/TF risk and make proceed/decline decision
Phase 4
Service Delivery & Monitoring
Provide service and maintain ongoing monitoring

Phase 1: Customer Onboarding

Phase 2: Verification & Screening

Phase 3: Risk Assessment & Approval

Phase 4: Service Delivery & Monitoring

Suspicious Activity (Can occur at ANY stage)

If you suspect money laundering or terrorism financing at any point, escalate immediately. Do NOT tip off the customer.

Key Reporting Timeframes

24 hours
SMR (terrorism-related)
3 business days
SMR (other suspicious matters)
10 business days
TTR (threshold transaction)
7 years
Record retention

Integration Architecture

A compliance platform needs to integrate with various government and commercial systems including AUSTRAC Online, DVS, ASIC, ABR, PEP/sanctions databases, and identity verification providers.

Government: AUSTRAC, DVS, ABR, ASIC, DFAT
Identity: FrankieOne, GreenID, Onfido, Jumio
Screening: Dow Jones, World-Check, ComplyAdvantage
Business: CRM, ERP, Payment Systems

About This Analysis

GetPost Labs conducted this technical study to understand the AML/CTF compliance requirements for Tranche 2 entities. We are developing RegTech solutions to help lawyers, accountants, real estate professionals, and conveyancers meet their obligations from 1 July 2026.

This workflow represents our interpretation based on publicly available legislation and AUSTRAC guidance. For official guidance, please visit austrac.gov.au.