DEADLINE: 1 JULY 2026

FAQs

Everything you need to know about Tranche 2 compliance.

Can't find your answer here? Contact us at +61 424 975 244 or email admin@pacificnetsolutions.com.au.

About Tranche 2

  • What is Tranche 2 and does it apply to my accounting firm?
    Tranche 2 refers to the second stage of Australia's Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) reforms. It extends AML/CTF obligations to a range of professional service providers — including accountants, lawyers, real estate agents and others. If your firm provides designated services such as tax advice, bookkeeping, company formation, or financial planning, you are very likely required to comply. We recommend speaking with us to confirm your obligations.
  • When do accounting firms need to enrol with AUSTRAC?
    Accounting firms that provide designated services under Tranche 2 must enrol with AUSTRAC by 1 July 2026. Enrolment is the first step and must be completed before you can submit your AML/CTF Program. We recommend enrolling as early as possible to avoid any last-minute issues.
  • How much time do firms have to become fully compliant?
    Firms have until 1 July 2026 to have their AML/CTF Program in place. However, building a compliant program takes time — you need to complete a risk assessment, draft your program, train your staff and establish ongoing compliance procedures. We recommend starting immediately as the process typically takes 4–8 weeks when done properly.
  • What happens if my firm misses the 1 July 2026 deadline?
    Missing the deadline carries serious consequences. AUSTRAC has the power to issue infringement notices, civil penalties and in serious cases, criminal prosecution. Fines for non-compliance can reach into the millions of dollars. Beyond financial penalties, your firm's reputation and ability to operate could be at risk. The good news is there is still time to act — contact us today and we'll get your firm compliant before the deadline.
  • How do I know which package is right for my firm?
    It depends on the size of your firm, the range of services you offer and how much support you need. The Essential Kit suits sole practitioners and small firms who are comfortable working through the documents independently. The Professional Kit is ideal for mid-size firms that want guided sessions to get it right. The Managed Compliance package is for firms that want us to handle everything end-to-end. Not sure? Book a free 30-minute scoping call and we'll recommend the right fit.

The Process

  • How long does it take to become compliant?
    For most accounting firms, the full compliance process takes between 4 and 8 weeks when working with us. This includes completing your ML/TF risk assessment, building your AML/CTF program, training your staff and enrolling with AUSTRAC. The timeline depends on your firm's complexity and how quickly you can engage with the process.
  • Do I need to enrol with AUSTRAC and how does that work?
    Yes — enrolment with AUSTRAC is mandatory for all reporting entities under Tranche 2. The process is done online through AUSTRAC's portal. Our Managed Compliance package includes a full AUSTRAC enrolment walkthrough where we guide you through every step. For other packages, we provide detailed instructions so you can complete it yourself.
  • What is a Suspicious Matter Report (SMR) and when do I need to lodge one?
    A Suspicious Matter Report (SMR) must be lodged with AUSTRAC when you have reasonable grounds to suspect that a transaction or activity is related to money laundering, terrorism financing or other criminal activity. As a reporting entity, you are legally required to submit an SMR within 24 hours for terrorism-related matters and 3 business days for all other suspicious matters. Our SMR Log and registers — included in all packages — help you track and manage this obligation.

The Documents

  • What documents will I receive and are they customisable?
    All packages include a full suite of compliance documents: an AML/CTF Program Kit in Word format, an ML/TF Risk Assessment in Excel, a CDD Forms Library, an SMR Log and Registers, and 17 Standard Operating Procedures. All documents are fully customisable — they are delivered in editable formats so you can tailor them to your firm's specific services, structure and risk profile.
  • Are your documents based on AUSTRAC's official guidance?
    Yes. All of our documents are built on AUSTRAC's January 2026 Accounting Sector Starter Kit and aligned with AUSTRAC's current regulatory guidance. We stay up to date with any changes to ensure our templates remain compliant and fit for purpose.
  • What is Customer Due Diligence (CDD) and what do I need to do?
    Customer Due Diligence (CDD) is the process of verifying the identity of your clients and assessing the risk they pose from a money laundering or terrorism financing perspective. Under Tranche 2, you are required to collect and verify identity information before providing designated services. Our CDD Forms Library provides all the forms you need, and our Managed Compliance package includes access to Sumsub's online KYC/AML screening platform to automate this process.

Working With Us

  • What is Sumsub and why do I need it?
    Sumsub is a leading global identity verification and AML screening platform. As an Authorised Sumsub Partner for ANZ, we integrate Sumsub's technology into your compliance program to automate Customer Due Diligence (CDD). Instead of manually verifying client identities, Sumsub handles KYC (Know Your Customer) and KYB (Know Your Business) checks digitally — saving your team significant time and reducing human error.
  • What happens after I purchase a package — what are the next steps?
    Once you purchase a package, our team will reach out within 1 business day to schedule your onboarding. We'll send you a short questionnaire about your firm so we can customise your documents. From there, we'll work through the process together based on your package — whether that's delivering your document kit, running guided sessions or managing the full compliance build on your behalf.
  • Do you offer ongoing support after the initial compliance setup?
    Yes. Our Managed Compliance package includes an annual review in Year 1 and two review and feedback sessions to ensure your program stays current. For all packages, we are available for follow-up support and can discuss ongoing compliance arrangements to suit your firm's needs as your obligations evolve over time.

1 July 2026 is a fixed deadline.
Compliance is achievable — with the right partner.

Start today and be audit-ready well before the deadline.