Around 90,000 Australian businesses became AUSTRAC reporting entities on 1 July. The obligations that hurt aren't the one-off ones — they're the ones that repeat on every new client, every matter, every year: due diligence, identity records, risk ratings, monitoring, seven-year record-keeping. That recurring load is exactly what well-governed automation is for.
The Act describes duties; your week fills up with the workflows underneath them. Here's the same list your AML advisor will give you — with the operational reality attached.
Identify and verify every new client; understand ownership structures; assess and record money-laundering risk before providing a designated service.
The workflow reality: ID collection, verification, risk-rating and file notes on every single onboarding — forever. This is the single biggest recurring load Tranche 2 adds.
A documented, risk-based program approved at the top of the business, reviewed and kept current as your services and risks change.
The workflow reality: the program is advice work — but keeping it operational (staff actually following it, evidence being captured) is a systems problem.
Monitor customer activity against expected behaviour; report suspicious matters to AUSTRAC within tight timeframes.
The workflow reality: someone has to notice, escalate, document and lodge — with the clock running. Unstructured, this lands on your most senior people at the worst times.
Retain CDD records, transaction records and program documentation for seven years, retrievable if AUSTRAC asks.
The workflow reality: "it's in an email somewhere" is not a retention system. Records need structure, retention rules and an audit trail from day one.
These are the four Tranche 2 workflow patterns we build inside your own Microsoft 365 tenant — fixed-scope, fixed-price, with the audit trail built in rather than bolted on.
A structured intake flow that collects identity documents and ownership information, chases what's missing, and files everything against the client record — so CDD starts complete instead of starting with email archaeology.
Your program's risk criteria turned into a guided checklist with AI-drafted summaries of the client file — a partner reviews and approves; the system records who decided what, and when.
Triggers your program defines, routed to the right person, with the supporting file assembled and the report paperwork drafted for human review — never lodged without one.
Retention rules in Microsoft Purview, records filed against matters automatically, and an audit trail that answers AUSTRAC's questions in minutes, not weekends.
We are not AML advisors, and this page is not legal or compliance advice. Your AML/CTF program and legal obligations belong with your AML specialist or lawyer — we're happy to work alongside them. What we build is the operational layer underneath the program: the workflows, records and audit trails that make it real. Security-first MSP since 2017; AI builds governed under the same discipline.
We're scoping Tranche 2 workflow automations with Australian firms now. Builds are fixed-price from $4,000 + GST with 6 months of support included — scope and price in a one-page Statement of Work before you spend a dollar. Not sure the numbers stack up? Run your onboarding hours through the ROI calculator — no email required.
If you provide designated services — for accountants and lawyers that includes managing client money, setting up companies and trusts, and conveyancing — you're likely an AUSTRAC reporting entity from 1 July 2026. Roughly 90,000 Australian businesses are newly captured. Confirm your specific position with your AML advisor or lawyer.
No — and be wary of anyone who both writes the program and marks their own homework. The program is advice work for an AML specialist or lawyer. We build the systems underneath it: onboarding workflows, CDD data handling, record-keeping and audit trails, so the program is operational rather than a binder on a shelf.
Builds are fixed-price from $4,000 + GST for a single flow (a typical build is from $8,500), with 6 months of support included and an optional retainer from $200/mo after that. Published pricing is on the Build & Operate page.
Enrolment is the first step. The ongoing load is operational: due diligence on every new client, monitoring and reporting, records retained for seven years. That recurring workflow is where automation earns its place — and where we'd start a scoping conversation.
Bring your AML advisor's requirements if you have them. If a Build isn't the right answer for your scale, we'll say so — "no action needed" is a real outcome here too.
SEE ALSO: ACCOUNTING FIRMS · LEGAL PRACTICES