Tranche 1 · Financial institutions
Practical AML/CTF operations for banks, credit unions and financial institutions
Deposit-taking, lending, payment services and securities dealing bring long-standing AUSTRAC obligations. Trancher supports efficient KYC/KYB, screening, monitoring and reporting so compliance teams can focus on higher-value risk work.
Am I captured?
Banks, credit unions, building societies and other ADIs, plus firms providing lending, payment or certain securities services, have been reporting entities for years.
Designated services include:
- Deposit-taking and account services
- Making loans or other credit available
- Payment and value-transfer services
- Dealing in securities or other financial products where those activities are designated
Tranche 2 does not remove those duties.
Your obligations
If you provide a designated service, you are a reporting entity. You must enrol with AUSTRAC, run a risk-based AML/CTF program, identify and monitor clients, keep records and report when the law requires it. The program already exists in most institutions. The operational gap is usually consistent KYC/KYB, screening and a file an auditor can follow — not writing the policy from a blank page.
AUSTRAC enrolment
Enrol with AUSTRAC and keep the enrolment current — including nominating a Compliance Officer. Enrolment is how AUSTRAC knows you are a reporting entity and how it contacts you.
Risk assessment
Document how your institution could be used for money laundering or terrorism financing — clients, services, delivery channels and geography — and keep that assessment current as your operations change.
AML/CTF program
Put in writing how the institution will meet its AML/CTF duties: who does what, how clients are identified, how higher-risk work is handled, how staff are trained and how you will check the program still works.
Customer due diligence
Identify the client (and beneficial owners where relevant), verify that identity, screen for PEPs, sanctions and adverse media, and apply extra checks when risk is higher. Repeat when circumstances change.
Reporting
Submit suspicious matter reports to AUSTRAC when you form a suspicion, and any other reports that apply to your services. Do not tip the client off that a report has been made or is being considered.
Record-keeping
Keep the program, risk assessment, identification records and transaction records for at least seven years so you can show AUSTRAC what you did and why.
How Trancher helps
Structured onboarding and verification, sanctions/PEP/adverse media screening, ongoing monitoring, SMR pathways and audit-ready records.
Risk assessment and AUSTRAC-aligned program builder
Client verification (KYC/KYB) with PEPs, sanctions and adverse media screening
Ongoing monitoring and risk scoring
Reporting support (SMRs)
Staff training modules
Audit-ready records and dashboard
Three clear paths
Choose the level of support that works for your institution — use Trancher within your existing AML/CTF operations, add expert support where needed, or have agreed activities managed for you.
1
Self-managed
Use Trancher within your existing AML/CTF program, with clear workflows and built-in guidance.
From $9.99 per week.
2
Self-managed + expert support
Use the platform day to day and bring in our compliance specialists when you need help with implementation, risk assessment, program updates, onboarding, training or operational reviews.
3
Fully managed by our experts
Ask our experienced compliance specialists to manage agreed AML compliance activities on your organisation’s behalf.
How long does it take?
Most firms move from start to operational compliance within weeks.
Days 1–7
Enrolment and risk assessment underway
Days 8–21
Workflows live and team trained
Thereafter
Fully operational and audit-ready
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View article →Questions from financial institutions
Am I captured?
Banks, credit unions, building societies and other ADIs, plus firms providing lending, payment or certain securities services, have been reporting entities for years. Tranche 2 does not remove those duties. Designated services include deposit-taking and account services, making loans or other credit available, payment and value-transfer services, and dealing in securities or other financial products where those activities are designated.
What are the deadlines?
Tranche 1 obligations have applied for many years. Enrolment must be kept current, including nomination of an AML/CTF Compliance Officer. There is no new Tranche 2 enrolment deadline for existing Tranche 1 entities; the focus is on ongoing compliance and program maintenance.
What goes in the program?
Your AML/CTF program must include a written risk assessment and the policies, procedures, systems and controls to manage ML/TF risks across the designated services you provide. Most institutions already have a program. The operational focus is usually consistent KYC/KYB, screening, ongoing monitoring and an audit-ready evidence trail rather than building a program from scratch.
What does CDD look like in practice?
Identify the client (and beneficial owners where relevant), verify identity, and screen for PEPs, sanctions and adverse media. Apply risk-based or enhanced due diligence as required. Ongoing monitoring is continuous. Records must demonstrate what was checked and why, and remain available for at least seven years.
How is KYC/KYB charged?
Every verification check triggers one transaction. If you are identifying individuals within an entity (for example directors, beneficial owners or authorised persons), each individual check is a separate transaction and is charged accordingly.
Disclaimer
This is a plain-English guide only and is not a determination of your firm’s status. Whether you are a reporting entity depends on the specific designated services you provide, the facts of each engagement, and the applicable items in the AML/CTF Act. If unsure, use the Am I in scope? guide or seek independent legal advice. Trancher does not provide legal advice.
Ready to simplify compliance?
Book a short overview or speak with our in-house specialists about the right path for your firm.