AUSTRAC’s AML/CTF Program Starter Kit for Tranche 2 businesses - Do You Need Support on Implementing?

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As a Tranche 2 business, the deadline to operationalise your AML/CTF Compliance Program is nearing!

AUSTRAC has handed you a head start, by rolling out the AML/CTF Program Starter Kit. The next move is yours!

AUSTRAC's guidance mentions that the Program Starter Kit 'once customised to your business and approved by a senior manager, it becomes your business’s AML/CTF program'.

So it is important to ask - if you adopt it as-is, does it reflect the nuances of your business? Your clients? Your services? Your risks?

It is critical to understand who the Program Starter Kit is for. Some of the conditions are:

- if you provide only one type / category of designated services (eg: only professional services; or only real estate brokering),

- have 15 or less personnel,

- usually deal with individuals who are Australian residents, with other business types less common,

- don't regularly deal with high-risk customers.

And these are just some of the conditions!

AUSTRAC's guidance recommends that if a Tranche 2 business does not meet the specified characteristics mentioned above, it must assess whether the Starter Kit is appropriate for it and identify any changes it needs to make.

The Starter Kit gives you the scaffolding - we can help turn it into a Program that fits your business!

16 March 2026

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Compliense Advisors is an AML/CTF and FinCrime compliance and risk management advisory firm.

Our experience includes implementing legislative changes; undertaking ML/TF risk assessment; setting up, implementing, uplifting AML/CTF program; and advising on AML/CTF and FinCrime compliance and risk matters.

The article above is for general awareness and informational purposes only. Please carefully evaluate your circumstances, and seek professional advice for your specific needs. You are responsible for your compliance obligations, and for any action taken or omitted. We are not a law firm, and do not provide legal advice.

Write to us on compliense@compliense.com.au. Visit our website for more such knowledge resources. You can also sign up for new articles and updates.