Australian Tranche 2 AML/CTF Reforms — Effective 1 July 2026

Your Complete AML/CTF Compliance Pack

Everything your business needs to meet its anti-money laundering obligations — professionally drafted, sector-specific, and ready to implement.

5 Industry Sectors7 Document Tiers240+ Documents95 Sector-Specific Policies⚠ Obligations Start 1 July 2026
Your Pack at a Glance
One complete compliance system across five regulated sectors — every document professionally drafted and sector-specific.
5
Industry Sectors
7
Document Tiers
95
Sector Policies
40
Operational Checklists
35
Excel Registers
25
Client Documents
20
Training Materials
25
Consultant Tools
What's In Each Tier?
Your compliance pack is structured across 7 tiers. Each tier has a clear purpose — from your master program document through to the tools your staff use every day.
T1

AML/CTF Program

Your master compliance document — one per sector

This is the single most important document in your pack. It is your business's official AML/CTF Program — a comprehensive, professionally drafted document (40–60 pages) that covers every compliance obligation in full. It must be approved by your principal or director, customised with your business details, and reviewed annually. Every business covered by the reforms must have one.

📋 1 document per sector  ·  Customisable white-label format
  • 📋AML/CTF Program (White-Label) — covers governance, risk assessment (EWRA), CDD procedures, transaction monitoring, suspicious matter reporting, training, record keeping, independent review, and sector-specific controls. Fill in the highlighted fields to make it yours.
T2

Sector-Specific Policies

19 individual policy documents — one for every compliance topic

Nineteen standalone policies that cover each compliance obligation in detail. All 19 are written specifically for your sector — a real estate agent's client due diligence policy is fundamentally different from a jeweller's. These sit alongside your T1 Program as your complete policy suite.

📄 19 policies × 5 sectors = 95 documents
  • 📄POL-001Governance & Risk Management Policy
  • 📄POL-002Enterprise-Wide Risk Assessment (EWRA) Policy
  • 📄POL-003Customer Due Diligence (CDD) Policy
  • 📄POL-004Enhanced Due Diligence (EDD) Policy
  • 📄POL-005Sanctions Screening Policy
  • 📄POL-006Politically Exposed Persons (PEP) Policy
  • 📄POL-007Transaction Monitoring & Reporting Policy
  • 📄POL-008Record Keeping & Retention Policy
  • 📄POL-009Staff Training & Competency Policy
  • 📄POL-010Third-Party Reliance & Outsourcing Policy
  • 📄POL-011Breach Management & Incident Response Policy
  • 📄POL-012Independent Review & Continuous Improvement Policy
  • 📄POL-013Client Acceptance & Exit Policy
  • 📄POL-014Funds Handling Policy
  • 📄POL-015Technology & Data Security Policy
  • 📄POL-016Proliferation Financing Policy
  • 📄POL-017Whistleblower & Internal Reporting Policy
  • 📄POL-018New Products, Services & Business Change Policy
  • 📄POL-019Correspondent & Referral Relationships Policy
T3

Operational Checklists

The forms your staff use on every client matter — 8 per sector

These are the practical, day-to-day working documents. Your staff use these on every client matter — at the front desk, in the file, at settlement. Each form is sector-specific and designed to make compliance straightforward without slowing down your work. Print them, save them digitally, or build them into your practice management system.

✅ 8 checklists × 5 sectors = 40 documents
  • T3-001Matter / Transaction Intake Check: confirms whether AML/CTF obligations apply to this new client or matter before you begin
  • T3-002CDD Checklist (Individual): step-by-step identity verification form for individual clients
  • T3-003CDD Checklist (Company / Trust / SMSF): identity and beneficial ownership verification for non-individual clients
  • T3-004Client Risk Scoring Sheet: assigns a Low / Medium / High / Critical rating to each client matter
  • T3-005Enhanced Due Diligence Workpaper: structured working document for high-risk client investigations
  • T3-006Source of Funds & Wealth Template: documents where a client's transaction money is coming from
  • T3-007Suspicious Matter Report Decision Tree: a clear yes/no flowchart guiding the decision to lodge an SMR with AUSTRAC
  • T3-008Annual CO Review Checklist: guides the Compliance Officer through the annual program review
T4

Excel Registers

Your ongoing compliance record-keeping system — 7 per sector

The law requires you to keep AML/CTF records for 7 years. These pre-built Excel registers are your system for doing that efficiently. They are maintained throughout the year and form the evidentiary backbone of your compliance program. Each register is sector-specific — conveyancers have a PEXA verification log, real estate agents have a FIRB register, jewellers have a cash transaction log.

📊 7 registers × 5 sectors = 35 spreadsheets
  • 📊REG-001 — Matter Alert Register: ongoing log of all red flags and alerts identified during client matters
  • 📊REG-002 — SMR Internal Register: confidential record of all Suspicious Matter Reports lodged with AUSTRAC
  • 📊REG-003 — Sanctions Screening Log: records every sanctions check conducted and its outcome
  • 📊REG-004 — Sector Register #1: e.g., PEXA Settlement Log (conveyancers) · TCSP Engagement Register (lawyers) · Client Funds Monitor (accountants) · TTR / Cash Transaction Log (jewellers) · FIRB Non-Resident Buyer Register (real estate)
  • 📊REG-005 — Sector Register #2: e.g., FIRB Register (conveyancers) · LPP Assertion Log (lawyers) · TCSP Register (accountants) · High-Value Transaction Register (jewellers)
  • 📊REG-006 — Staff Training Register: tracks who was trained, when, topics covered, and assessment results
  • 📊REG-007 — Breach Register: records any compliance failures and remediation steps taken
T5

Training Materials

Everything needed to train your staff — 4 documents per sector

The law requires you to train all relevant staff before they start work and annually thereafter. These materials are ready to use — no additional preparation needed. All training content is sector-specific with scenarios and examples drawn from your industry.

🎓 4 documents × 5 sectors = 20 documents
  • 🎓T5-001 — Staff Competency Quiz: 20 questions with sector-specific scenarios; 80% pass mark required; includes answer key
  • 📝T5-002 — Staff Training Acknowledgement Form: signed form confirming each staff member completed training and understands their obligations
  • 🔍T5-003 — Scenario-Based Case Studies: real-world money laundering scenarios specific to your sector, designed to build practical recognition skills
  • 📢T5-004 — Training Presenter Guide: complete run-of-show for the Compliance Officer conducting the annual training session
T6

Client-Facing Documents

Professional documents you give directly to your clients — 5 per sector

These documents are designed to be handed to your clients. They explain what information you need from them, why you need it, and what their rights are — in plain, professional language that builds client confidence rather than creating friction. Each document meets all legal requirements while remaining easy to understand.

✉️ 5 documents × 5 sectors = 25 documents
  • ✉️T6-001 — Client CDD Explanation Letter: explains to your client why you need to verify their identity under the new laws — professionally worded to maintain trust
  • 📋T6-002 — Client Onboarding / Identification Form: the form your client completes to provide their identity information
  • 📋T6-003 — Beneficial Ownership Declaration: for clients who are companies, trusts, or other entities — confirms who ultimately owns or controls the organisation
  • 🔒T6-004 — AML/CTF Privacy Notice: explains how you collect, use, and protect client information — complies with the Privacy Act 1988 (Cth)
  • 📤T6-005 — Client Exit Letter Template: professionally worded template for ending a client relationship — carefully drafted to comply with the tipping-off prohibition
T7

Compliance Consultant Tools

Professional tools for implementing and reviewing compliance programs — 5 per sector

These are the professional tools your compliance consultant uses when setting up, auditing, and reviewing your compliance program. They reflect the full implementation and ongoing assurance lifecycle — from initial client scoping through to formal independent review.

🔎 5 documents × 5 sectors = 25 documents
  • 📖T7-001 — Implementation Guide: comprehensive step-by-step guide for setting up the complete compliance program from scratch
  • 🖥️T7-002 — AUSTRAC Enrolment Walkthrough: screen-by-screen guide to completing the AUSTRAC enrolment process
  • 🔍T7-003 — Gap Analysis Questionnaire: structured questionnaire to assess what a business already has in place and what gaps need to be addressed
  • 📋T7-004 — Client Intake Questionnaire: collects all the information needed about a business before building or reviewing their compliance program
  • 🔎T7-005 — Independent Review Workpaper: formal structured workpaper for conducting the mandatory independent review of the entire AML/CTF program
What's Included for Your Sector
Select your industry below to see every document included in your sector pack and exactly what it covers.

🏠 Conveyancers — Complete Pack Contents

50 documents · Key sector features: PEXA digital settlement controls, FIRB / FRCGW obligations, vendor-side CDD, client trust account, off-the-plan transactions

What makes this sector pack unique: The only sector with a dedicated PEXA Settlement Verification Log and explicit bank account substitution fraud controls. Covers both buyer-side and vendor-side obligations. Includes FIRB approval and Foreign Resident Capital Gains Withholding (FRCGW) procedures.
T1 · AML/CTF Program
AML/CTF Program — Conveyancers (White-Label)
Your complete master compliance document. Covers all conveyancing designated services, PEXA controls, FIRB/FRCGW, trust account, off-the-plan procedures, and sector-specific red flags.
T2 · 19 Policies
CONV-POL-001 through POL-019
Full conveyancer-specific policy suite. POL-014 covers client trust account with PEXA controls. POL-007 monitoring covers PEXA workspace changes as a primary red flag.
T3 · Checklist
T3-001 — Matter Intake Designated Service Check
Confirms at the outset of every matter whether AML/CTF obligations apply to the conveyancing service being provided.
T3 · Checklist
T3-002 — CDD Checklist (Individual Buyer or Vendor)
Step-by-step identity verification for individual buyers and vendors — includes FIRB status check for non-resident buyers.
T3 · Checklist
T3-003 — CDD Checklist (Company / Trust / SMSF)
Identity and beneficial ownership verification for non-individual buyers and vendors including corporate trustees.
T3 · Checklist
T3-004 — Client Risk Scoring Sheet
Assigns a risk rating to each conveyancing matter including property type, buyer origin, and funding source risk factors.
T3 · Checklist
T3-005 — EDD Workpaper (Property Settlement)
Enhanced due diligence working document for high-risk matters including offshore buyers and complex entity purchasers.
T3 · Checklist
T3-006 — Source of Funds & Wealth Template
Documents where the purchase funds are coming from — required for large or elevated-risk transactions.
T3 · Checklist
T3-007 — SMR Decision Tree (Conveyancing)
Guides your Compliance Officer through the decision to lodge a Suspicious Matter Report with AUSTRAC.
T3 · Checklist
T3-008 — Annual CO Review Checklist
Structured checklist for the Compliance Officer's annual program review and EWRA update.
T4 · Excel Register
REG-001 — Matter Alert Register
Ongoing log of all compliance alerts identified during conveyancing matters — date, matter, red flag, CO action taken.
T4 · Excel Register
REG-002 — SMR Internal Register (Confidential)
Confidential record of all Suspicious Matter Reports lodged — CO access only. Retained for 7 years.
T4 · Excel Register
REG-003 — Sanctions Screening Log
Records every sanctions check: date, person/entity screened, lists checked, and outcome.
T4 · Excel Register
REG-004 — Client Funds Monitoring Log
Tracks trust account receipts and disbursements for AML/CTF purposes — source of funds, amounts, and third-party payments.
T4 · Excel Register · Sector-Specific
REG-005 — PEXA Settlement Verification Log ⭐
Unique to conveyancers — records telephone verification of bank account details before every PEXA settlement. Critical fraud prevention control.
T4 · Excel Register
REG-006 — Staff Training Register
Tracks who was trained, when, what was covered, and assessment results. Required evidence for AUSTRAC audits.
T4 · Excel Register
REG-007 — Breach Register
Records any compliance failures, how they were remediated, and whether voluntary disclosure to AUSTRAC was made.
T5 · Training
T5-001 — Competency Quiz (Conveyancing AML/CTF)
20 questions with conveyancing-specific scenarios including PEXA fraud, trust account risks, and FIRB. 80% pass mark.
T5 · Training
T5-002 — Staff Training Acknowledgement Form
Signed confirmation that each staff member completed training and understands their AML/CTF obligations.
T5 · Training
T5-003 — Scenario-Based Case Studies
Real-world conveyancing ML/TF scenarios: bank account substitution fraud, offshore buyer, off-the-plan trust structure abuse.
T5 · Training
T5-004 — Training Presenter Guide
Complete run-of-show for the CO to deliver annual staff training — timing, talking points, and discussion questions.
T6 · Client Document
T6-001 — Client CDD Explanation Letter
Professional letter explaining to property clients why identity verification is required under the new laws.
T6 · Client Document
T6-002 — Client Onboarding / Identification Form
Form for clients to provide their identity and transaction information — covers individuals, companies, and trusts.
T6 · Client Document
T6-003 — Beneficial Ownership Declaration
Declaration for company and trust purchasers / vendors confirming ultimate ownership and control.
T6 · Client Document
T6-004 — AML/CTF Privacy Notice (Conveyancing)
Explains how client information is collected and used — complies with the Privacy Act 1988 (Cth).
T6 · Client Document
T6-005 — Client Exit Letter Template
Carefully drafted exit letter for ending a client relationship — neutral language compliant with the tipping-off prohibition.
T7 · Consultant Tool
T7-001 — Implementation Guide (Conveyancing Practices)
Step-by-step guide for setting up the complete compliance program for a conveyancing practice.
T7 · Consultant Tool
T7-002 — AUSTRAC Enrolment Walkthrough
Screen-by-screen guide to completing AUSTRAC enrolment for a conveyancing practice.
T7 · Consultant Tool
T7-003 — Gap Analysis Questionnaire
Structured questionnaire to assess a conveyancing practice's existing compliance status and identify gaps.
T7 · Consultant Tool
T7-004 — Client Intake Questionnaire
Gathers all information needed about a conveyancing practice before building their compliance program.
T7 · Consultant Tool
T7-005 — Independent Review Workpaper
Formal workpaper for conducting the mandatory independent review of a conveyancing practice's AML/CTF program.

⚖️ Lawyers — Complete Pack Contents

49 documents · Key sector features: All 9 Table 6 designated services, legal professional privilege (LPP) framework, TCSP controls, trust account, PEXA

What makes this sector pack unique: The most comprehensive sector — covers all nine Table 6 designated services including TCSP (acting as director, trustee, or nominee). Includes a full legal professional privilege (LPP) framework explaining how privilege and AML/CTF obligations interact. Contains dedicated TCSP and LPP registers.
T1 · AML/CTF Program
AML/CTF Program — Lawyers (White-Label)
Master compliance document covering all 9 Table 6 items with in/out scope examples, a full LPP framework (Part B), TCSP-specific controls (Part D.6), trust account and PEXA controls, and 7 categories of sector-specific red flags.
T2 · 19 Policies
LAW-POL-001 through POL-019
Full lawyer-specific policy suite. POL-003 CDD covers all 9 Table 6 items. POL-004 EDD covers TCSP mandatory EDD. POL-007 monitoring covers LPP and tipping-off interaction. POL-009 training covers the LPP Form procedure.
T3 · 8 Checklists
T3-001 through T3-008
All 8 operational checklists — T3-001 checks all 9 Table 6 items at matter intake. T3-002/003 include LPP assessment field. T3-005 EDD Workpaper covers TCSP enhanced checks.
T4 · 7 Excel Registers
REG-001 to REG-007 including sector-specific:
REG-004 — TCSP Engagement Register: tracks all matters where the firm acts as director, trustee, nominee, or registered office (Table 6 items 7–9) · REG-005 — LPP Assertion Log: records all instances where legal professional privilege was asserted in an AML/CTF context
T5 · 4 Training Documents
T5-001 through T5-004
Quiz includes LPP and TCSP scenarios. Case studies cover shelf company transfers, corporate trust structures, and TCSP nominee typologies specific to legal practice.
T6 · 5 Client Documents
T6-001 through T6-005
All 5 client-facing documents in legal-profession language — covering retainer commencement CDD through to tipping-off safe exit letters.
T7 · 5 Consultant Tools
T7-001 through T7-005
T7-003 Gap Analysis covers all 9 Table 6 services. T7-005 Independent Review Workpaper includes TCSP register review and LPP procedure assessment.

🧮 Accountants — Complete Pack Contents

49 documents · Key sector features: TCSP controls, SMSF client CDD, client funds management, cash-intensive business clients, company and trust creation

What makes this sector pack unique: Includes TCSP controls for accountants acting as directors, trustees, or company officers. Contains SMSF-specific CDD procedures including ATO registration verification and member identification. Covers the elevated risk of cash-intensive business clients with revenues inconsistent with their business profile.
T1 · AML/CTF Program
AML/CTF Program — Accountants (White-Label)
Master compliance document covering accounting designated services including TCSP, SMSF, trust and company creation, client funds management, and business restructuring. Includes sector-specific EWRA and red flag library.
T2 · 19 Policies
ACC-POL-001 through POL-019
Full accountant-specific policy suite. POL-003 includes SMSF CDD procedures. POL-004 EDD covers TCSP mandatory EDD triggers. POL-014 covers client funds (no trust account). POL-009 training covers SMSF and TCSP-specific risks.
T3 · 8 Checklists
T3-001 through T3-008
All 8 checklists — T3-003 includes SMSF-specific checks (ATO registration verification, SFN confirmation, member identification). T3-005 EDD Workpaper covers TCSP engagements.
T4 · 7 Excel Registers
REG-001 to REG-007 including sector-specific:
REG-004 — Client Funds Monitoring Log: tracks client funds held in connection with accounting designated services · REG-005 — TCSP Services Register: tracks all engagements where accountants act as director, trustee, or company officer
T5 · 4 Training Documents
T5-001 through T5-004
Quiz covers SMSF client risks, TCSP obligations, and cash-intensive business client red flags. Case studies include SMSF property purchase ML typologies.
T6 · 5 Client Documents + T7 · 5 Consultant Tools
T6-001 to T6-005 · T7-001 to T7-005
All client-facing and consultant tool documents in accounting-profession language. T7-003 Gap Analysis covers TCSP procedures and SMSF client onboarding.

🏡 Real Estate Agents — Complete Pack Contents

49 documents · Key sector features: FIRB / FRCGW controls, buyer substitution protocols, off-the-plan transactions, deposit trust account, non-resident buyer identification

Important sector note: Property management, leasing, and rental management are NOT captured by the AML/CTF reforms. Obligations apply only to the sale and purchase of real estate. This important carve-out is clearly documented throughout all pack documents so your clients understand exactly where obligations begin and end.
T1 · AML/CTF Program
AML/CTF Program — Real Estate Agents (White-Label)
Master compliance document covering real estate sale/purchase designated services. Clearly documents the leasing exclusion. Covers FIRB/FRCGW procedures, buyer substitution as a critical risk, off-the-plan controls, and deposit trust account management.
T2 · 19 Policies
REA-POL-001 through POL-019
Full real estate-specific policy suite. POL-003 CDD includes FIRB verification procedures. POL-004 EDD treats buyer substitution as a Critical trigger. POL-007 monitoring red flags are specific to real estate transactions. POL-009 training covers FIRB and FRCGW.
T3 · 8 Checklists
T3-001 through T3-008
Named "Transaction Intake" (not "Matter Intake") — reflects real estate practice. T3-002 CDD includes FIRB status check field for non-resident buyers. T3-004 risk scoring includes buyer substitution and off-market pricing indicators.
T4 · 7 Excel Registers
REG-001 to REG-007 including sector-specific:
REG-005 — FIRB Non-Resident Buyer Register: tracks all non-resident buyers, FIRB approval status, FRCGW clearance certificate status, and settlement outcomes — unique to the real estate sector
T5 · 4 Training Documents
T5-001 through T5-004
Quiz covers buyer substitution scenarios, FIRB obligations, and off-market pricing red flags. Case studies include foreign buyer ML typologies and off-the-plan settlement fraud scenarios.
T6 · 5 Client Documents + T7 · 5 Consultant Tools
T6-001 to T6-005 · T7-001 to T7-005
All documents in real estate agent language. T7-003 Gap Analysis specifically covers FIRB and FRCGW compliance procedures. T7-005 Independent Review Workpaper includes assessment of non-resident buyer controls.

💎 Jewellers & Precious Metals Dealers — Complete Pack Contents

49 documents · Key sector features: $10,000 AUD cash threshold, Threshold Transaction Reports (TTR), structuring prevention, proliferation financing controls for bullion

What makes this sector pack unique: The most distinct sector — obligations are triggered by TRANSACTION VALUE (cash at or above $10,000) rather than by service type. Includes mandatory Threshold Transaction Reporting (TTR) obligations not present in other sectors. Contains an enhanced Proliferation Financing section covering precious metals and bullion-specific risks including unusual specification requests and DPRK/Iran exposure.
T1 · AML/CTF Program
AML/CTF Program — Jewellers & Precious Metals (White-Label)
Master compliance document built around the $10,000 threshold. Covers the aggregation rule (same-day transactions), TTR obligations, structuring offence, cash handling controls, customer identification at the counter, and proliferation financing risk for bullion and precious metals.
T2 · 19 Policies
JWL-POL-001 through POL-019
Full HVD-specific policy suite. POL-003 CDD trigger is VALUE-based (not service-based). POL-007 includes TTR lodgement procedures and structuring SMR triggers. POL-014 is "Cash and Payment Handling Controls" (no trust account). POL-016 Proliferation Financing includes an enhanced bullion-specific section.
T3 · 8 Checklists
T3-001 through T3-008
T3-001 intake checklist assesses the $10,000 threshold including same-day aggregation. T3-004 risk scoring includes structuring indicators and unusual specification requests. T3-007 SMR Decision Tree includes structuring and TTR assessment pathways.
T4 · 7 Excel Registers
REG-001 to REG-007 including two sector-specific:
REG-004 — TTR / Cash Transaction Log: mandatory log of all cash transactions with TTR lodgement deadlines tracked · REG-005 — High-Value Transaction Register: records all transactions at or above the $10,000 threshold with source of funds notes and CDD status
T5 · 4 Training Documents
T5-001 through T5-004
Quiz covers the aggregation rule, TTR obligations, structuring red flags, and bullion proliferation financing indicators. Case studies include walk-in cash structuring scenarios and unusual bullion specification requests.
T6 · 5 Client Documents + T7 · 5 Consultant Tools
T6-001 to T6-005 · T7-001 to T7-005
All documents in HVD/retail language. T7-003 Gap Analysis covers threshold aggregation compliance. T7-005 Independent Review Workpaper includes assessment of TTR lodgement compliance and structuring controls.
How to Use Your Pack
Each tier plays a different role. Here is the recommended sequence for getting up and running before 1 July 2026.
1

Start With T1

Read your T1 AML/CTF Program. Fill in the highlighted yellow fields with your business details. Have your principal approve and sign it.

2

Enrol With AUSTRAC

Use T7-002 (AUSTRAC Enrolment Walkthrough) to complete your enrolment online at austrac.gov.au. Enrolment opens 31 March 2026.

3

Set Up Your Registers

Open the 7 T4 Excel registers and add your business name. These registers are active from 1 July 2026 — your staff maintain them from that date.

4

Train Your Staff

Use T5-004 (Presenter Guide) to run your initial training session. Staff complete T5-001 (Quiz) and sign T5-002 (Acknowledgement Form).

5

Operate With T3

From 1 July 2026: use the T3 checklists on every client matter. Start with T3-001 (Intake Check) on every new client before doing anything else.

6

Review Annually

Every year: update your EWRA, run refresher training, complete T3-008 (Annual CO Review), and update your T1 Program if your business has changed.