AML/CTF compliance questions, answered
Everything Australian accountants, lawyers, real estate agents, and jewellers ask about AUSTRAC Tranche 2 and how AML Mate helps.
Who needs to comply with AUSTRAC AML/CTF regulations?
Under Tranche 2 reforms effective 1 July 2026, accountants, tax agents, lawyers, conveyancers, real estate agents, and dealers in precious metals/stones (jewellers) who provide "designated services" must comply. This includes services like managing trust accounts, conveyancing, company/trust formation, and transactions over $10,000.
What happens if I don't comply by 1 July 2026?
Non-compliance penalties include up to $16,500 per contravention for companies and $3,300 for individuals. Serious or systemic breaches can attract civil penalties up to $31.3 million. AUSTRAC can also issue infringement notices, enforceable undertakings, and remedial directions.
Do I need a lawyer to create my AML/CTF program?
No. AUSTRAC explicitly states that businesses can create their own AML/CTF program using the free Starter Kits they provide. AML Mate automates this process using AUSTRAC's official guidance, so you don't need expensive consultants. However, we recommend having a compliance professional review your program for complex situations.
How does AML Mate generate my compliance plan?
AML Mate uses a deterministic rules engine based on AUSTRAC's official Starter Kits, not AI hallucinations. You answer questions about your business, services, and risk factors. Our engine maps your answers to AUSTRAC's framework and generates a tailored AML/CTF program with CDD procedures, risk assessment, and EDD triggers. Every recommendation cites its AUSTRAC source.
What is Customer Due Diligence (CDD)?
CDD is the process of identifying and verifying your clients before providing designated services. It includes collecting government-issued photo ID, verifying identity (optionally via Electronic Identity Verification), identifying beneficial owners for companies/trusts, and screening against PEP and sanctions lists. AML Mate walks you through the entire CDD process step by step.
How much does AML Mate cost?
AML Mate starts at $49/month, a fraction of the $3,000-$8,000/year that traditional compliance consultants charge. The free compliance check requires no signup. We offer a 14-day free trial on all paid plans so you can generate your compliance plan before committing.
Do I need an AML/CTF compliance officer?
Yes. Every reporting entity must appoint an AML/CTF compliance officer who is responsible for overseeing your AML/CTF program, ensuring staff training, and managing reporting obligations. For small businesses, this is typically the business owner or managing partner. You must notify AUSTRAC of your compliance officer, though transitional rules provide extra time for this notification.
What are the transitional rules for existing customers?
Transitional rules mean you do not need to immediately re-do Customer Due Diligence for all existing clients. You should prioritise new clients and higher-risk existing clients first, then progressively apply CDD to your remaining client base. AUSTRAC has stated: "We don't expect perfection immediately, but we expect to see genuine effort to comply."
Is AML Mate a substitute for legal advice?
No. AML Mate is an information tool based on AUSTRAC's publicly available guidance and Starter Kits. It does not constitute legal or compliance advice. We recommend consulting a licensed compliance professional before submitting your AML/CTF program to AUSTRAC, especially for complex business structures.