All articles
Operations 22 April 2026 5 min read

Tranche 2 readiness: a 12-point self-assessment

A quick scorecard to gauge how close your firm is to a defensible AML/CTF program before 1 July 2026.

By James Carter

If you score 10+ you are in good shape. 6–9 and you have meaningful work left. Below 6 and you should engage a provider this month.

The 12 questions

  • Have you mapped which of your services are designated under the Act?
  • Have you completed a written business risk assessment?
  • Do you have a Part A program signed by a named compliance officer?
  • Do you have a Part B program covering individual and non-individual CDD?
  • Have you enrolled (or scheduled enrolment) with AUSTRAC?
  • Do you have an electronic ID verification tool selected and configured?
  • Do you have sanctions/PEP screening configured for new and existing customers?
  • Have all relevant staff completed AML training in the last 12 months?
  • Do you have a documented SMR/TTR escalation path?
  • Have you scheduled or completed an independent review?
  • Are you keeping records in a system that can be exported on demand?
  • Has senior management or the board reviewed the program in the last 12 months?
Practical next step

Stop reading. Get matched.

Tell us your sector — see a free, independent shortlist of vetted providers instantly on the next screen.

Get matched