23 questions across 7 topics. Based on Australian law and AUSTRAC guidance.
From 1 July 2026, the following businesses must comply: accountants, bookkeepers, tax agents, lawyers/solicitors, conveyancers, real estate agents, trust and company service providers, and dealers in precious metals and stones. If your business provides any designated service under the AML/CTF Act 2006, you are a reporting entity. AUSTRAC estimates this will bring over 100,000 additional businesses into the compliance framework.
If you were providing designated services on 1 July 2026, you must enrol with AUSTRAC by 29 July 2026. Enrolment opened on 31 March 2026 and is free. Failing to enrol is a criminal offence under the AML/CTF Act 2006. Go to austrac.gov.au/enrol to enrol directly.
Yes — every Tranche 2 reporting entity must have a written AML/CTF Program before providing designated services. The program must document how your business will identify, manage and mitigate money laundering and terrorism financing risks. It must cover: customer due diligence procedures, staff training, ongoing monitoring, and AUSTRAC reporting. CompliDesk includes an 8-section AML/CTF Program builder that generates a signed, print-ready PDF document in minutes — aligned to AUSTRAC's Accounting Program Starter Kit.
Customer Due Diligence (CDD) means verifying your client's identity, understanding the nature of your relationship with them, and assessing their ML/TF risk. You must complete CDD before providing any designated service. CDD includes: verifying identity documents (KYC), screening against DFAT sanctions lists and PEP databases, assessing source of funds, and understanding the purpose of engagement. CompliDesk guides you through all CDD steps with a 5-step compliance workflow for every client.
A Politically Exposed Person (PEP) is someone who holds or recently held a prominent public position — such as a politician, judge, senior military officer, government official, or executive of a state-owned enterprise. PEPs and their close associates require Enhanced Due Diligence (EDD). CompliDesk's AI-powered CDD screening automatically checks and flags PEPs during the screening process.
An SMR must be filed with AUSTRAC when you have reasonable grounds to suspect a transaction or client is connected to money laundering or terrorism financing. File as soon as practicable after forming that suspicion — there is no minimum dollar threshold. Critically: you must not tip off the client that an SMR has been filed (this is a criminal offence). CompliDesk includes a guided SMR workflow and XML generation for AUSTRAC portal upload.
A TTR must be filed when a client makes a cash transaction of AUD $10,000 or more. This applies to physical cash — electronic transfers generally don't trigger TTR obligations. TTRs must be filed within 10 business days. CompliDesk generates TTRs automatically and produces AUSTRAC-compliant XML for portal upload.
EDD is additional verification required for high-risk clients. EDD is triggered when: the client is a PEP, the client is from a high-risk jurisdiction, the transaction involves unusual amounts, or the ML/TF risk assessment rates the client as high risk. EDD typically requires: certified copies of ID, source of wealth documentation (bank statements, tax returns), beneficial ownership declarations, and documented approval to proceed. CompliDesk shows an EDD checklist automatically for high-risk clients.
Yes. AUSTRAC requires every reporting entity to appoint an AML/CTF Compliance Officer (AMLCO) at management level. The AMLCO is responsible for overseeing your AML/CTF program, ensuring staff are trained, and liaising with AUSTRAC. For sole traders, this is typically the owner. CompliDesk's AML/CTF Program builder includes a section to formally nominate and document your AMLCO — required by AUSTRAC.
AUSTRAC requires all AML/CTF records to be kept for a minimum of 7 years. This includes: customer identification records, risk assessments, transaction records, SMRs and TTRs filed, staff training records, and your AML/CTF Program. CompliDesk stores all records securely for 7 years with a one-click audit trail export for AUSTRAC inspections.
Penalties can be severe. Civil penalties can reach millions of dollars per breach — AUSTRAC fined CBA $700 million and Westpac $1.3 billion for serious violations. For Tranche 2 entities, AUSTRAC has indicated an education-first approach in year one, but will take enforcement action for serious or deliberate non-compliance. Criminal penalties also apply for tipping off clients about SMRs (up to 2 years imprisonment).
Beneficial ownership refers to the natural persons who ultimately own or control a company, trust or other legal structure. AUSTRAC requires you to identify and verify the beneficial owners of any corporate client. For companies, verify all directors and shareholders with 25%+ ownership. For trusts, identify the trustee, settlor and beneficiaries. CompliDesk includes a beneficial ownership questionnaire in its 8-question CDD workflow.
KYC (Know Your Customer) refers specifically to identity verification — confirming a client is who they say they are using identity documents. CDD (Customer Due Diligence) is broader — it includes KYC plus understanding the business relationship, assessing ML/TF risk, and screening against sanctions lists and PEP databases. AUSTRAC requires both as part of your onboarding process.
For most small-to-medium Tranche 2 entities, CompliDesk provides all the tools needed to comply without engaging a consultant. It guides you through all 8 AUSTRAC requirements and generates your AML/CTF Program document. Note: CompliDesk is a software tool and does not constitute legal advice. For complex situations or high-risk practices, consider engaging an AML/CTF specialist alongside CompliDesk. Typical consultant fees are $5,000-$15,000 upfront — CompliDesk starts at $39/month.
Manual AML/CTF compliance typically costs: $10,000-$25,000/year in staff time, plus $5,000-$15,000 upfront for a consultant to write your AML program, and $8-15 per KYC verification using standalone tools. CompliDesk replaces all of this from $39/month including KYC checks, automated CDD screening, AML program builder, and AUSTRAC reporting — saving thousands per year.
Yes — if you provide bookkeeping services that involve handling client money, managing trust accounts, or processing transactions on behalf of clients, you are likely a Tranche 2 reporting entity. Bookkeepers who prepare BAS, manage payroll or handle client funds are generally captured. You must enrol with AUSTRAC, have an AML/CTF Program, and complete CDD on your clients. CompliDesk is built specifically for bookkeepers and other small Tranche 2 firms.