Meet Tranche 2 AML/CTF Obligations with VerifiMe
VerifiMe is an Australian Tranche 2 AML/CTF compliance platform supporting KYC, customer due diligence, PEP/sanctions screening, and audit-ready record keeping. From 1 July 2026, it enables lawyers, accountants, real estate agents, and jewellers meet AUSTRAC obligations with minimal friction.
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Built by the team solving Australian AML/CTF challenges since the 2006
New Tranche 2 AML/CTF Obligations. Effective 1st July 2026.
The new Tranche 2 obligations introduce AML/CTF compliance requirements for certain professions and businesses that were previously outside the regime. These obligations largely mirror those already imposed on existing reporting entities, adjusted for the scale and risk profile of the newly regulated sectors where applicable businesses must:
Develop and Maintain an AML/CTF Program
Entities must design policies, systems, procedures, controls to manage money laundering, terrorism financing, and proliferation risk.
Appointment of a Compliance Officer / Responsible Person
A “fit and proper” individual must be appointed to oversee day-to-day AML/CTF obligations, ensure compliance, escalate issues, and liaise with AUSTRAC.
Customer Due Diligence (CDD) / Know Your Customer (KYC) / Know Your Business (KYB)
Before providing designated services, entities must identify and verify their customers (individuals, companies, trusts), as well as beneficial owners, assess risk, and apply simplified or enhanced measures as appropriate.
Record Keeping & Documentation
Retain records relating to the AML/CTF program, client identification, transaction records, risk assessments, training records, audits/independent reviews, and compliance decisions for at least 7 years.
Independent Review / Evaluation
Periodic independent evaluation (audit) of the AML/CTF program to ensure effectiveness and compliance.
Governance, Training & Oversight
Governance oversight by senior management or board, staff training on AML/CTF obligations, internal compliance checks.
New Tranche 2 AML/CTF Obligations. Effective 1st July 2026.
VerifiMe is Australia's secure identity verification platform for professional services. Confirm client identities in minutes, meet your KYC and AML/CTF obligations, and streamline onboarding — without storing sensitive documents or creating data breach liability.
Handle client data without the liability
Handle client data without the liability
Fully Tranche 2-ready from day one
Configurable rules for tailored compliance
Cut onboarding time dramatically
Cut onboarding time dramatically
Eliminate document storage risk entirely
Deliver audit-ready customer due diligence
See VerifiMe in action
How It Works
From compliance chaos to seamless onboarding in three steps
Customer Submits ID to VerifiMe
Your customer completes document verification, biometric checks, and compliance questions — just once. Their verified credentials are stored securely in their VerifiMe wallet.
VerifiMe Processes ID
When your customer engages your services, they share their verified credentials with a tap. No documents to upload, no forms to complete, no friction.
You confirm and proceed
You receive proof of verified credentials, not their sensitive personal data. Your compliance rules engine instantly confirms whether they meet your AML/CTF requirements and assesses risk.
AUSTRAC-ready from day one
VerifiMe was built by the team that's been solving AML/CTF challenges for Australian businesses since the Act came into force in 2006.
This isn't a generic international platform retrofitted for local rules — it's Australian compliance infrastructure, purpose-built for Australian professionals.
VerifiMe's unified platform automates your entire customer due diligence process. Design KYC and KYB workflows matched to your risk appetite, connect directly to government verification services, and screen against global databases for sanctions, adverse media, and PEPs.
Set your policies once; automation handles the rest. And here's what makes VerifiMe different: your clients store their verified credentials in a reusable wallet. When they've already been verified by another VerifiMe business, you access that verification at no cost — no redundant checks, no wasted time.
Ready to meet compliance requirements with VerifiMe®?
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AML/CTF Tranche 2 Timeline
Critical dates and preparation milestones
Early 2025
Preparation Phase
Assess current processes, identify gaps, begin AML/CTF program development. Early adopters gain competitive advantage.
August to October 2025
Rules Finalisation
AUSTRAC finalises AML/CTF Rules after second consultation. Finalisation of core guidance is made so detailed requirements become clear.
January 2026
Guidance Released
AUSTRAC releases detailed sector guidance. Use this to finalise your AML/CTF program and train your compliance officer before the deadline.
31 March 2026
AUSTRAC Enrolment
Deadline to enrol with AUSTRAC. Late enrolment risks daily penalties and may delay your ability to provide designated services.
1 July 2026
Compliance Mandatory
AML/CTF obligations commence. Non-compliance carries criminal penalties. No extensions available.
VerifiMe®: Tailored for Your Industry
By minimising manual checks and data storage, VerifiMe helps law firms, accountants, real estate agents and jewellers/precious metal dealers implement AML/CTF compliance efficiently, securely, and in line with Australia’s evolving regulatory framework.
Legal & Professional Services
Your Challenge:
Maintaining legal professional privilege while meeting new AML/CTF reporting obligations.
VerifiMe® Solution:
Verify client identity without storing their documents. You receive attestations, not PII — maintaining privilege while meeting AUSTRAC requirements for conveyancing, trust matters, and financial transactions.
Legal professional privilege protected
Legal professional privilege protected
Conveyancing identity verification streamlined
Conveyancing identity verification streamlined
Trust and company formation compliance
Trust and company formation compliance
Accountants & Tax Advisers
Your Challenge:
Implementing comprehensive due diligence without burdening clients or slowing onboarding.
VerifiMe® Solution:
Streamline onboarding for SMSF setup, trust management, and high-value advisory. Automated risk assessments handle complex entity structures — beneficial owners, corporate trustees, and multi-layered trusts.
SMSF setup verification simplified
SMSF setup verification simplified
Corporate structure compliance automated
Corporate structure compliance automated
Ongoing client monitoring included
Ongoing client monitoring included
Real Estate Professionals
Your Challenge:
Verifying buyers and sellers in high-value transactions — a sector AUSTRAC has flagged as high-risk for money laundering.
VerifiMe® Solution:
Instant buyer/seller verification with beneficial ownership transparency. Protect against property-based money laundering while accelerating legitimate transactions.
Buyer/seller verification in minutes
Buyer/seller verification in minutes
Beneficial ownership transparency
Beneficial ownership transparency
High-value transaction monitoring
High-value transaction monitoring
Jewellers & Precious Metal Dealers
Your Challenge:
High-value cash transactions and portable assets make this sector a money laundering target.
VerifiMe® Solution:
Enhanced due diligence for high-value cash transactions. Source of funds verification and ongoing customer monitoring for luxury goods transactions.
Cash transaction source verification
Cash transaction source verification
Enhanced due diligence automated
Enhanced due diligence automated
Luxury goods transaction monitoring
Luxury goods transaction monitoring
Read More
Understand how firms like yours are preparing or understand more about Tranche 2 implications
Privacy Is Now Part of Your AML/CTF Obligations — What the OAIC's Updated Guidance Means for Your Business
Privacy considerations must be front of mind for every business captured by the tranche 2 AML/CTF reforms.
30 March 2026
Your Clients' Consent Is All You Need. Here's Why That's a Big Deal.
When accounting, legal and real estate practices start exploring how to meet their AML/CTF Tranche 2 identity verification obligations, most assume there's a significant administrative hurdle waiting for them — a government registration process, a formal participation agreement with the Attorney-General's Department, and all the paperwork, waiting periods, and compliance overhead that comes with it.
With VerifiMe, there isn't. And that difference matters more than most practices realise.
16 March 2026
Why VerifiMe's Status as a Government-Approved Gateway Service Provider Matters for Your Practice
VerifiMe is an approved Gateway Service Provider (GSP) to the Australian Government's Document Verification Service (DVS) — listed on the Attorney-General's Department's official approved GSP register as GreenGate FinTech Holdings (VerifiMe).
16 March 2026
Frequently Asked Questions
What will be a lawyers AML/CTF obligations under Tranche 2?
Tranche 2 refers to the second phase of Australia’s anti-money laundering and counter-terrorism financing (AML/CTF) regulatory reforms, extending regulations to designated non-financial businesses and professions (DNFBPs). This includes lawyers, accountants, real estate agents, and trust and company service providers. The goal is to align Australia with international standards, close regulatory gaps, and combat financial crime more effectively.
The AML/CTF Amendment Act introduces regulatory obligations for new 'designated services', so any entities providing such a service with a geographical connection to Australia will be subject to the AML/CTF Act.
What is the source of these new regulations?
These changes are summarised under the Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2024 (the Amendment Act). This legislation reforms Australia's Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act)
When do the main changes related to these reforms take effect?
Many of the changes related to AML/CTF program requirements, customer due diligence (CDD) requirements, and value transfer obligations come into effect on March 31, 2026.
What is the fundamental shift in regulatory approach?
The reforms move the focus from a traditional compliance-based approach to a risk-based, outcomes-oriented approach. This means reporting entities must now follow an outcomes-based framework, tailoring their AML/CTF controls based on the specific risks posed by their customers. This ensures that resources are allocated more effectively to mitigate potential money laundering (ML) and terrorism financing (TF) risks.
How do the new rules change AML/CTF Program requirements?
Major updates shift the focus to effective, tailored AML/CTF measures. Key changes include:
- Risk Assessment: Reporting entities must now identify and assess risks related to ML, TF, and proliferation financing (PF).
- Flexibility: The previous requirement to separate the AML/CTF program into Part A and Part B is repealed, allowing organisations to structure their program based on their needs, as long as it meets the requirements of the AML/CTF Act and Rules.
- Leadership Responsibility: The new framework emphasises the explicit role of governing bodies and senior management in overseeing ML/TF/PF risk and ensuring compliance.
- Compliance Officer: It is now an explicit requirement to appoint a fit and proper AML/CTF compliance officer responsible for implementing the program.
How do the new rules change AML/CTF Program requirements?
Major updates shift the focus to effective, tailored AML/CTF measures. Key changes include:
- Risk Assessment: Reporting entities must now identify and assess risks related to ML, TF, and proliferation financing (PF).
- Flexibility: The previous requirement to separate the AML/CTF program into Part A and Part B is repealed, allowing organisations to structure their program based on their needs, as long as it meets the requirements of the AML/CTF Act and Rules.
- Leadership Responsibility: The new framework emphasises the explicit role of governing bodies and senior management in overseeing ML/TF/PF risk and ensuring compliance.
- Compliance Officer: It is now an explicit requirement to appoint a fit and proper AML/CTF compliance officer responsible for implementing the program.
What are the key changes to Customer Due Diligence (CDD) obligations?
The changes aim for a more targeted and flexible approach to mitigating risks, particularly those associated with higher-risk customers and transactions. CDD is separated into two categories based on timing:
- Initial CDD: Required before providing a designated service, this involves identifying the customer’s ML/TF/PF risk profile, completing screening for targeted financial sanctions, and establishing if the customer is a politically exposed person (PEP).
- Ongoing CDD: Requires monitoring and managing ML/TF/PF risks throughout the customer relationship, which includes monitoring for suspicious activity and updating the customer's risk profile as triggers arise.
Do the rules require different levels of customer checking?
Yes, the level of checks applied depends on the risk profile:
- Simplified CDD: May be applied when the ML/TF/PF risk is assessed as low and no enhanced CDD triggers apply, which helps reduce the compliance burden for low-risk customers.
- Enhanced CDD: Must be applied when the ML/TF/PF risk is high or in specified circumstances, such as when dealing with a foreign PEP or when a suspicious matter reporting obligation arises
How does this reform package affect value transfers and reporting?
The new laws introduce changes related to value transfer services, which collectively cover electronic funds transfer instructions and designated remittance arrangements, and importantly, now explicitly apply to the transfer of virtual assets.
- New Reporting: International Value Transfer Service (IVTS) reporting will replace the current international funds transfer instruction (IFTI) reports. IVTS reporting applies to transfers of money, virtual assets, or other property.
- Reporting Obligation: The reporting obligation will now lie with the reporting entity closest to the Australian customer.
- Virtual Asset Wallets: There is a new reporting obligation for transfer activity to or from unverified self-hosted virtual asset wallets.
- New Reporting: International Value Transfer Service (IVTS) reporting will replace the current international funds transfer instruction (IFTI) reports. IVTS reporting applies to transfers of money, virtual assets, or other property
Are there stronger penalties for non-compliance under the new rules?
Yes. The initial CDD requirements and the new obligations in the AML/CTF Act are directly subject to civil penalty provisions. This means that failing to identify and verify a customer's identity before providing a designated service, for example, now carries a direct civil penalty. This increases the regulatory risk of non-compliance.
Contact Support
Need help or have a question? Our support team is here to assist you.
support@verifime.com
Phone
+ 61 (02) 7208 7799
Hours
Monday–Friday
8.30 am–5.30 pm
Address
L5, 137-139 Bathurst Street, Sydney, NSW 2000
VerifiMe Australia Pty Ltd is a wholly-owned subsidiary of Greengate Fintech Holdings
ACN 664 286 515
ABN 97 664 286 515
VerifiMe Australia Copyright 2026
VerifiMe acknowledges the Traditional Custodians of country throughout Australia and their connections to land, sea and community.
We pay our respect to their Elders past and present and extend that respect to all Aboriginal and Torres Strait Islander peoples today.