‍1. Governance & Policy Framework

• Appoint an AML/CTF Compliance Officer.
• Review and update your AML/CTF Program (Part A and Part B).
• Conduct a risk assessment tailored to Tranche 2 customer types (e.g., real estate agents, accountants).
• Ensure board and senior management are briefed on Tranche 2 implications.

2. Customer Due Diligence (CDD) / Know Your Customer (KYC)

• Enhance due diligence procedures for high-risk sectors (e.g., DNFBPs).
• Implement or upgrade eKYC tools for onboarding.
• Collect and verify Ultimate Beneficial Owner (UBO) information for business clients.
• Strengthen record-keeping practices for all CDD steps.

3. Transaction Monitoring & Reporting

• Ensure transaction monitoring rules reflect updated typologies (e.g., red flags for DNFBPs).
• Test and tune transaction monitoring systems.
• Review procedures for submitting Suspicious Matter Reports (SMRs), TTRs, and IFTIs.
• Implement a regular internal review process for compliance reporting.

4. Third-Party Risk Management

• Map relationships with high-risk third parties and referral partners.
• Conduct KYB checks on all business clients.
• Revisit agreements with partners to clarify AML/CTF roles and responsibilities.
• Perform third-party due diligence and risk classification.

5. Technology & Automation

• Assess current systems for scalability and automation potential.
• Consider RegTech solutions for onboarding, monitoring, and reporting.
• Ensure integration with AUSTRAC reporting APIs (where applicable).
• Establish audit trails for all automated decisions.

6. Training & Awareness

• Develop a staff training plan for Tranche 2 reforms.
• Deliver tailored AML/CTF training to product, sales, and customer support teams.
• Educate customers on their responsibilities (esp. DNFBPs) and your onboarding requirements.
• Keep training records and track staff completion.

7. Documentation & Review

• Update internal procedures to reflect Tranche 2 changes.
• Schedule annual AML/CTF Program reviews.
• Prepare a briefing paper for investors, partners, or regulators on your compliance approach.
• Create a communication plan for upcoming changes.

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