AML/CTF Tranche 2: what you actually have to do now

For most of the professions caught by it, the hardest thing about AML/CTF Tranche 2 is not any single requirement. It is realising that it is not a single requirement at all.

Since 1 July 2026, Tranche 2 of the AML/CTF Act has made reporting entities of professionals who have never dealt with AUSTRAC before — real estate agents, conveyancers, accountants, and a range of other professional services. Different professions, different designated services, but the same core obligations and the same clock. And the obligation is not a form you file once. It is a system you have to run, continuously, alongside the actual job.

It isn't one task — it's a program

Here is the shape of what "being compliant" now means, stripped of the acronyms:

- Enrol with AUSTRAC and appoint someone as your compliance officer. - Assess your risk — document the money-laundering and terrorism-financing risks your specific business faces. - Write the program — the policies, processes and forms that say how you will manage those risks. - Do customer due diligence on every customer, before you provide the service — identify them, verify them, risk-rate them. - Screen for sanctions — check customers against the sanctions lists, at onboarding and beyond. - Keep it current — ongoing reviews, trigger events, record-keeping, and reporting for the full retention period.

None of it is optional, and all of it takes hours you would rather spend with clients. That is the real problem Tranche 2 created for small firms: not that the rules are impossible to understand, but that running them properly is a standing administrative load that most practices were never staffed for.

What software can honestly do about it — and what it can't

It is worth being precise here, because the market for compliance software is about to fill up with promises.

Software cannot make your compliance decisions for you. It cannot tell you whether a particular customer is high-risk, or whether a matter is suspicious, or how the Act applies to your firm. Anything sold as a "done for you" compliance button deserves your scepticism — no tool can be that, and the ones that imply it are the ones to walk away from.

What good software can do is take the repeatable administrative work — the drafting, the screening, the record-keeping, the review dates — and make it fast and consistent. You still own every compliance decision. The tool just means you are not rebuilding the paperwork from scratch each time, or checking sanctions lists by hand, or keeping review dates in your head.

That distinction — software, not advice — is the line we hold, and it is the one worth insisting on from anyone selling into this space.

How Curlew Comply approaches it

Curlew Comply is our answer to that administrative load. It is built around AUSTRAC's own program starter kits for the sectors now in scope, so the structure your inspector recognises is the structure you are working in.

- Set up your program. Generate your risk assessment and your policy and process documents, rebuilt faithfully from AUSTRAC's sources for your sector — real estate, accounting or conveyancing — and customised once to your business. - Run customers through guided CDD. Onboarding forms matched to the customer type, with sanctions screening built into the flow — checked automatically against the DFAT Consolidated List, which incorporates UN Security Council listings. - Keep it current. Record due diligence as you go, set review dates when you complete the CDD, and generate from a library of 20+ AUSTRAC-aligned forms as your program runs.

It is hosted on Microsoft Azure in Australia, built in Far North Queensland by a licensed real estate agent with 35 years across property, operations and asset management. The obligation does not shrink. The admin around it does.

Curlew is $79–$149 a month — $79 for a solo practitioner, $149 for a business with team seats for up to ten — with a 14-day free trial and no lock-in. The honest test is to run it against your own setup before a dollar changes hands.

Try it against your own workflow

Start the trial tonight — it takes minutes, not a meeting. Scan the code, or head to www.curlewcomply.au.

Curlew Comply is a software tool. It does not provide AML/CTF advice. For how the law applies to your firm, that belongs to AUSTRAC's guidance or your own adviser, and we will happily point you there.

Curlew Comply is a Budduns platform. See what it does, or start a free trial.