With the New Year upon us and what feels like absolutely everyone racing to settle, Tranche 2 might seem like just another thing on your already overflowing to-do list. ‘A put off until later problem’, as many people we speak to have put it. And for the most part, they’d be right. You definitely don’t need to tackle everything before the AUSTRAC industry specific guidelines are released at the end of January.
Here are three things that you can safely put on the back-burner until then:
Drafting a full AML/CTF program. You won’t need to finalise your program until the second quarter of 2026. In fact, sector-specific guidance hasn’t even been released by AUSTRAC yet, so there’s no need to start drafting your program just yet.
Deep-dive policy writing. Detailed procedures are best tackled once all the guidance is finalised, and you have a more thorough understanding of exactly how Tranche 2 is going to impact your specific business and clients.
AUSTRAC starter kits. Small, low-complexity businesses will be able to access starter program kits to help complete your risk assessment and develop your policies. However, they’re not out yet, with current ETA suggesting AUSTRAC will release these around the end of January 2026.
However, if you want to start 2026 calmly, and have your Tranche 2 compliance under control, there are a couple of things that shouldn’t wait:
Understanding what Tranche 2 will apply to. Knowing what Tranche 2 is all about, how it will apply (at a high level) to your business, and the different compliance obligations that will be coming into effect will make January (and the rest of 2026) far less overwhelming.
Giving some thought to your Compliance Officer. Every business will need one, and simply identifying who that might be is a great low-effort win.
Remember that your Tranche 2 preparation doesn’t have to be rushed or stressful. 1 July 2026 might seem far away, but a little clarity now will make these changes far more manageable.
To learn more about what Tranche 2 means for your business and how easyAML is here to help, visit our website.
