DIY, consultant, or head in the sand: the three ways accounting practices are handling Tranche 2

Building AML-READY meant asking a simple question early on: how are accounting practices actually planning to handle Tranche 2? In conversations with principals — and in watching the broader profession grapple with it — three patterns keep emerging. We're going to be honest about all three, including which one most practices are currently sitting in.

Option 1: Wait and see

"AUSTRAC isn't going to come after a small practice. I'll deal with it when there's actually an enforcement action."

This is, based on conversations with small practices, one of the most common responses right now. And to be fair, it's not entirely irrational — AUSTRAC's enforcement focus has historically been on larger, systemic failures rather than small firms.

But this approach misses two things.

The first is reputational risk. AUSTRAC publishes enforcement actions publicly, and professional bodies such as CPA Australia and CA ANZ pay close attention to member compliance with regulatory obligations. The impact of a finding can extend well beyond any financial penalty.

The second is timing. The obligations don't wait for enforcement — they apply from the commencement of Tranche 2. The longer practices delay, the bigger the gap between obligation and readiness.

Option 2: Hire a consultant

For complex or higher-risk practices — such as those with significant trust work, international clients, or higher transaction volumes — engaging an AML consultant is often the right approach. They can build a tailored risk assessment and AML/CTF program specific to your practice.

A few practical realities to factor in:

• Good consultants are in high demand and often booked out
• Bespoke programs typically cost several thousand dollars
• Most consultants focus on the framework: risk assessment and program design — the training, staff communication, and day-to-day implementation tools usually still sit with the practice

Option 3: DIY using AUSTRAC's starter kit

AUSTRAC has published a free Accounting Program Starter Kit designed for small, low-complexity practices. It's a solid starting point, requires no specialist legal knowledge, and is a completely viable path for many small firms. It helps you structure your risk assessment and build your AML/CTF program.

What it doesn't typically provide is:

• Staff training and completion tracking
• Certificates of completion for audit purposes
• Ready-to-use staff and client communication templates
• Ongoing AMLCO support resources for day-to-day questions

Where AML-READY fits

We're not a full compliance consultancy — and we're not trying to replace one.

AML-READY is the training and implementation layer that sits on top of whichever path you choose. If you're delaying — no judgement. If you're using a consultant — we complement their work. If you're doing it yourself — we help you implement it in practice.

Whether you're doing it yourself, working with a consultant, or somewhere in between — it's the simplest way to get your team trained and your audit trail in place.